USA v. Spann et al

1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
UNITED STATES OF AMERICA *
v. * Criminal Action No. RDB-06-179
JERMAINE BELL, *
Defendant. *
* * * * * * * * * * * * *
MEMORANDUM OPINION
On August 27, 2008, Defendant Jermaine Bell (“Defendant” or “Mr. Bell”) pled guilty
to Possession of a Firearm in Furtherance of a Drug Trafficking Offense Resulting in Death,
in violation of 18 U.S.C. § 924(j). (ECF No. 247.) Pursuant to Federal Rule of Criminal
Procedure 11(c)(1)(C), the Government and the Defendant agreed upon a sentence in the
range of 312 to 396 months (or 26–33 years) of incarceration.1 (ECF No. 200.) In accordance
with the plea agreement, on December 23, 2008, this Court sentenced Mr. Bell to 360 months
(or 30 years) of incarceration with credit for time served in federal custody since December
11, 2006, followed by three years of supervised release (ECF No. 247.) Mr. Bell is now 50
years old and currently incarcerated at Yazoo City Medium FCI, in Yazoo City, Mississippi,
with a projected release date of January 20, 2033. Find an Inmate, FEDERAL BUREAU OF
PRISONS, https://www.bop.gov/inmateloc (search by register number: 33031-037) (last
accessed Jan. 12, 2026).
1 In a Rule 11(c)(1)(C) plea agreement, the defendant agrees to plead guilty or no contest to a charged or lesser
offense, and the government’s attorney agrees to a specific sentence or sentencing range. FED. R. CRIM. P.
11(c)(1)(C). Once the court accepts the plea agreement, the sentence or sentencing range in the plea agreement
becomes binding on the Court. Id.
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Presently pending before this Court is Defendant’s pro se Motion for a Reduced
Sentence Pursuant to 18 U.S.C. § 3582(c)(1)(A) (ECF No. 560), as Supplemented by appointed
counsel (ECF No. 565) (collectively, (“Motion for Compassionate Release” or “Defendant’s
Motion”). See (ECF No. 562, Order appointing CJA counsel).2 In his Motion, Mr. Bell argues
that his traumatic childhood and youth at the time of the offense, the length of his sentence
as compared to those of similar defendants, and his rehabilitation while incarcerated
demonstrate “extraordinary and compelling” reasons to warrant a sentence reduction. See
generally (ECF Nos. 560, 565). The Government has responded in opposition (ECF No. 570),
and Defendant has replied (ECF No. 572). The Court has reviewed the relevant filings, and
no hearing is necessary. See Local Rule 105.6 (D. Md. 2025). For the reasons that follow, Mr.
Bell’s Motion for a Reduced Sentence Pursuant to 18 U.S.C. § 3582(c)(1)(A) (ECF Nos. 560,
565) is DENIED.
BACKGROUND
On February 7, 2008, a federal grand jury sitting in Baltimore returned a Fourth
Superseding Indictment (ECF No. 146) charging Mr. Bell with (1) Conspiracy to Distribute
Heroin in violation of 21 U.S.C. § 846; (2) Conspiracy to Possess Firearm in Crime of Violence
in violation of 18 U.S.C. § 924(o); (3) Possession of a Firearm in Furtherance of a Drug
Trafficking Crime Resulting in Death, in violation of 18 U.S.C. § 924(j); (4) Possession of a
Firearm in Furtherance of a Drug Trafficking Crime Resulting in Death in violation of 18
U.S.C. § 924(j); (5) Possession of a Firearm in a Drug Trafficking Crime in violation of 18
2 Via Memorandum Order (ECF No. 532) dated November 4, 2022, this Court denied Defendant’s previous
Motion for Compassionate Release (ECF No. 516). Defendant then filed a pro se Motion for Compassionate
Release (ECF No. 560), and this Court by Order (ECF No. 562) dated May 27, 2025, appointed CJA counsel,
see (ECF No. 565), who Supplemented that Motion (ECF No. 565).
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U.S.C. § 924(c); and (6) Possession of a Firearm in Furtherance of a Drug Trafficking Crime
Resulting in Death in violation of 18 U.S.C. § 924(j). (ECF No. 146.) On August 27, 2008, Mr.
Bell pleaded guilty pursuant to Federal Rule of Criminal Procedure 11(c)(1)(C) to Count Four
of the Fourth Superseding Indictment, which charged him of firearm possession in
furtherance of a drug-trafficking crime resulting in death. (ECF No. 200.) In his plea
agreement, Mr. Bell agreed to certain factual and sentencing stipulations. (Id.) The following
factual history is derived from those stipulations.
Between 1996 and at least December 2001, Mr. Bell was the leader of a narcotics-
trafficking organization known as “R-N-G.” (Id. Attach. A.) Mr. Bell’s organization distributed
heroin at multiple street-level shops under several “brand names,” including “Big White.” (Id.)
In 2001, Mr. Bell became involved in a turf dispute with a rival drug organization and issued
contracts for the murders of Samuel Garrett—the leader of the rival drug organization—and
several of his associates, including Kenyatta Harris, Angelo Stringfellow, and Torrence Jonson.
(Id.) On June 26, 2001, in furtherance of Mr. Bell’s orders, co-Defendants Corey Smith,
Linwood Smith, Sean Sterling, William Deshields, and Andre Brown located Mr. Stringfellow
in his car in Baltimore, Maryland. (Id.) Co-Defendants Mr. Deshields and Mr. Brown shot Mr.
Stringfellow in his parked car and, several hours later, Mr. Stringfellow died from his wounds.
(Id.) A female standing near the vehicle was also shot and wounded. (Id.)
On February 7, 2008, Mr. Bell was charged with, among other charges, three counts of
Possession of a Firearm in Furtherance of a Drug Trafficking Crime Resulting in Death in
violation of 18 U.S.C. § 924(j). (ECF No. 146.) On August 27, 2008, Mr. Bell entered into a
plea agreement pursuant to which he pleaded guilty to Possession of a Firearm in Furtherance
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of Drug Trafficking Resulting in Death, for the murder of Mr. Stringfellow. See generally (ECF
No. 200.) Pursuant to the Federal Sentencing Guidelines, U.S.S.G § 2A1.1, the parties
stipulated that the base offense level was 43 but ultimately agreed to an adjusted offense level
of 41. (Id. at 4.) The parties further agreed under Rule 11(c)(1)(C) to a sentence in the range
of 312 to 396 months of imprisonment. (Id. at 4–5.) On December 23, 2008, this Court
sentenced Mr. Bell to a term of imprisonment of 360 months, followed by three years of
supervised release. (ECF No. 247.) Mr. Bell appealed his case to the U.S. Court of Appeals for
the Fourth Circuit, which affirmed his conviction and sentence on January 4, 2010. (ECF No.
295.) Mr. Bell then filed a Petition for Writ of Certiorari to the United States Supreme Court,
which was denied on May 3, 2010. Bell v. United States, 559 U.S. 1114 (2010). Since his direct
appeal, Mr. Bell has sought various forms of post-conviction relief,3 including the pending
Motion for Compassionate Release. (ECF No. 560, 565.)
STANDARD OF REVIEW
The First Step Act of 2018, Pub. L. No. 115–391, 132 Stat. 5194, established significant
changes to the procedures involving compassionate release from federal prison. Prior to the
First Step Act, 18 U.S.C. § 3582(c)(1)(A)(i) provided the Bureau of Prisons (“BOP”) with sole
discretion to file compassionate release motions with the Court. With the passage of the First
Step Act, defendants are now permitted to petition federal courts directly for compassionate
release whenever “extraordinary and compelling reasons” warrant a reduction in sentence.
3 In 2012, Mr. Bell filed a Motion for Reconsideration, which resulted in the reopening of his case, see (ECF
Nos. 397, 413), but was ultimately denied, see (ECF No. 424). He has filed two motions to vacate his conviction
under 28 U.S.C. § 2255, both of which this Court denied. (ECF No. 337, 395, 396, 487, 493, 494.) In addition,
Mr. Bell has sought sentence reductions in November 2014 and 2021, see (ECF No. 419, 516). This Court
denied all prior motions for sentence reductions, see (ECF Nos. 493, 494, 532).
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The Act permits a defendant to seek a sentence reduction after he “has fully exhausted all
administrative rights to appeal a failure of the Bureau of Prisons to bring a motion on the
defendant’s behalf or the lapse of 30 days from the receipt of such a request by the warden of
the defendant’s facility, whichever is earlier.” 18 U.S.C. § 3582(c)(1)(A). Once these mandatory
conditions are satisfied, this Court may authorize compassionate release upon a showing of
“extraordinary and compelling reasons” warranting a reduction and after weighing the factors
presented in 18 U.S.C. § 3553(a). 18 U.S.C. § 3582(c)(1)(A)(i).
ANALYSIS
I. Administrative Exhaustion Requirements
Mr. Bell has exhausted his administrative remedies. Before a defendant may file a
motion for compassionate release, one of the mandatory conditions laid out in 18 U.S.C.
§ 3582(c) requires him to either “fully exhaust[] all administrative rights to appeal a failure of
the Bureau of Prisons to bring a motion on the defendant’s behalf” or demonstrate that thirty
days have lapsed “from the receipt of such a request by the warden of [his] facility, whichever
is earlier.” 18 U.S.C. § 3582(c)(1)(A). In this case, Mr. Bell has met his administrative
exhaustion requirements by demonstrating that, through counsel, he submitted an
administrative request for a reduced sentence, and the warden of FCI Yazoo City failed to
respond within 30 days. See (ECF No. 565, Ex. A.)
II. Extraordinary and Compelling Circumstances
Notwithstanding his exhaustion of administrative remedies, Mr. Bell has not
demonstrated the extraordinary and compelling circumstances necessary to reduce his
sentence. The United States Sentencing Commission is charged with defining “what should
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be considered extraordinary and compelling reasons for sentence reduction” under 18 U.S.C.
§ 3582(c)(1)(A). 28 U.S.C. § 994(t). The Commission has identified six possible circumstances
that viewed separately or together may establish “extraordinary and compelling reasons” for a
sentence reduction. These reasons include:
(1) a serious medical circumstance of the defendant;
(2) a defendant who is 65 years old that suffers from serious health deterioration
and has served either 10 years or 75 percent of his or her term;
(3) the death or incapacitation of an immediate family member;
(4) the defendant being a victim of abuse while in custody;
(5) other reasons of similar gravity as (1)–(4); and
(6) unusually long sentence if the defendant has served at least ten years.
U.S.S.G. § 1B1.13(b)(1)–(6).
Mr. Bell provides three broad arguments that he contends present “extraordinary and
compelling reasons” to reduce his sentence: (1) his traumatic childhood and relative youth at
the time of the offense (ECF No. 560 at 8–10; ECF No. 565 at 9–14); (2) the disparity between
his sentence and similarly situated defendants in comparable cases (ECF No. 560 at 5–8; ECF
No. 565 at 14–18); and (3) his rehabilitation while incarcerated.4 (ECF No. 560 at 10–13; ECF
No. 565 at 18–19.) In Opposition, the Government asserts that Mr. Bell’s age and background
do not justify a sentence reduction because he was twenty-six at the time of the crime, and
that is “not an age that is generally associated with youthful impulsivity.” (ECF No. 570 at 5.)
4 In his pro se Motion for Compassionate Release, Mr. Bell proffers four arguments that he contends are
“extraordinary and compelling reasons” to reduce his sentence to time served: (1) the disparity between his
sentence and the average sentence for murder; (2) his relative youth at the time of the offense; (3) his
rehabilitation while incarcerated; (4) his belief that he no longer presents a threat to the community. (ECF No.
560.) In the Supplementary Motion for Compassionate Release, Mr. Bell’s counsel asserted three arguments to
justify the requested reduction: (1) his traumatic childhood and youth status at the time of the offense; (2) the
disparity between his 360-month sentence and similarly or more culpable defendants in comparable cases; and
(3) his rehabilitation while incarcerated. (ECF No. 565.) Although somewhat overlapping, the Court considers
all arguments across both filings and, to the extent any claims are raised solely in a pro se capacity, those claims
are treated less stringently. Erickson v. Pardus, 551 U.S. 89, 94 (2007).
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Additionally, the Government emphasizes that there is neither a change in the law nor a
disparity between Mr. Bell’s sentence and those of similarly situated defendants. (Id. at 7.)
Finally, the Government argues Mr. Bell’s rehabilitation is insufficient when considered
alongside the other factors. (Id. at 11–12.) In reply, Mr. Bell argues that courts can consider
youth in combination with sentencing disparities and rehabilitation to form extraordinary and
compelling reasons that warrant a sentence reduction (ECF No. 572 at 1). The Court
addresses each argument in turn.
Although youth is not a reason explicit under U.S.S.G. § 1B1.13(b), federal courts
generally consider youth at the time of the offense to fall under the “other reasons” category
enumerated in U.S.S.G. § 1B1.13(b)(5). See, e.g., United States v. Moses, Crim. No. CCB-02-0410-
2, 2023 WL 4421569, at *4 (D. Md. July 10, 2023) (recognizing youth as a possible
extraordinary and compelling reason that could warrant sentence reduction); United States v.
Taylor, Crim. No. CCB-02-0410-3, 2023 WL 4407593, at *4 (D. Md. July 7, 2023) (considering
youth status at the time of the offense as a potential extraordinary and compelling reason);
United States v. Brown, No. 2:11-cr-152, 2024 WL 3357836, at *5 (E.D. Va. July 10, 2024)
(considering youth under U.S.S.G. § 1B1.13(b)). The Supreme Court has acknowledged that
juveniles, defined as individuals under age eighteen, have “[a] lack of maturity and an
underdeveloped sense of responsibility” that leaves them vulnerable to negative influences and
pressure. Roper v. Simmons, 543 U.S. 551, 569 (2005) (quoting Johnson v. Texas, 509 U.S. 350, 367
(1993)). See also Graham v. Florida, 560 U.S. 48, 68–69, 72 (2010) (emphasizing that youth
immaturity and irresponsibility render juveniles more susceptible to negative pressure); Miller
v. Alabama, 567 U.S. 460, 470–72 (2012) (acknowledging that juveniles’ culpability is less than
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adults’ because juveniles’ brains are not yet fully developed, resulting in immaturity,
impulsivity, and recklessness). As such, courts have historically considered youth-status as a
mitigating factor in sentencing and postconviction relief. Miller, 567 U.S. at 470–72; Taylor,
2023 WL 4407593, at *4.
Although Mr. Bell faced early exposure to drug-related crimes and began engaging in
such crimes at the age of fourteen,5 he was twenty-six at the time he contracted to murder
several people in connection with a drug rivalry in this case. (ECF No. 565, at 9.) Thus, he
does not qualify as a “juvenile” for the purposes of the Supreme Court’s precedents regarding
youth culpability. See, e.g., Roper, 543 U.S. at 569 (discussing characteristics of juveniles under
the age of 18 at the time of their offenses). Even where federal courts have considered youthful
age as a mitigating factor or a factor justifying compassionate release, their consideration of
youth generally extends only to defendants who were twenty-four or younger at the time of
their crimes. See, e.g., United States v. McCoy, 981 F.3d 271, 286 (4th Cir. 2020) (acknowledging
ages nineteen to twenty-four may still constitute youth status depending on the relative
circumstances); United States v. Burleigh, 145 F.4th 541, 546 (4th Cir. 2025) (recognizing that
youth status may extend to age twenty-four, or even age twenty-five, depending on a
defendant’s criminal history and the seriousness of the offense). Mr. Bell falls outside of this
“youthful offender” category because he was twenty-six years old at the time of the offenses
5 Mr. Bell began selling drugs at age fourteen and began running a small crew at age fifteen. He was
intermittently placed in the custody of the Department of Juvenile Services and received a six-year state
sentence. He was released again in 1995 at the age of twenty. (ECF No. 565, at 4.)
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in this case. Put differently, Mr. Bell does not qualify as a “juvenile” or a “youthful offender”
for relief based on youth-status.6
Nor is Mr. Bell’s sentence disparately long as compared to those of similarly situated
defendants. A disparity in sentencing may constitute an “extraordinary and compelling”
reason for sentence reduction. United States v. Brown, 78 F.4th 122, 124, 126 (4th Cir. 2023). In
his Motion, Mr. Bell argues that if he were to be sentenced today, he would receive a lesser
sentence. (ECF No. 565, at 15–16.) This argument is most consistent with U.S.S.G. §
1B1.13(b)(6), which contemplates a sentence reduction where a defendant can demonstrate
that: (1) he “received an unusually long sentence”; (2) he “has served 10 years of the term of
imprisonment”; and (3) due to the change in law, there is a “gross disparity between the
sentence being served and sentence likely to be imposed at the time this motion is filed.” §
1B1.13(b)(6).
In this case, Mr. Bell fails to satisfy the elements required to demonstrate that he
received an unusually long sentence. While he has served at least ten years of his sentence, his
sentence is not unusually long, and there is no evidence of a gross disparity in sentencing. This
6 Moreover, even if Mr. Bell’s age warranted categorization of juvenile status, youth at the time of offense alone
is insufficient to justify sentence reduction. Instead, youth must be combined with other extraordinary
circumstances, such as sentencing disparities, previous criminal history, and rehabilitation, to justify sentence
modification. See United States v. Little, No. 4:97-cr-41-1, 2025 WL 1862997, at *3–7 (E.D. Va. July 7, 2025)
(granting compassionate release in part due to the defendant’s relative youth at the time of the offense, when
considered alongside the gross disparity in the defendant’s unusually long sentence, low recidivism risk, and his
rehabilitation efforts). By the time Mr. Bell committed the instant offense at the age of twenty-six, he possessed
an extensive criminal record. Cf. Little, 2025 WL 1862997, at *3–7 (noting defendant’s sparse criminal history
in conjunction with his age of 23 to 24 years old at time of offenses justified relief); (ECF 565 at 12). Moreover,
while his traumatic childhood—including early exposure to substance abuse and violence—is certainly
troubling, his childhood history is not so unusual as to constitute an extraordinary and compelling reason for a
sentence reduction. See, e.g., Miller, 567 U.S. at 470–72 (emphasizing that childhood circumstances, unless
unusually troubling, do not amount to an extraordinary or compelling reason that warrants a sentence
reduction).
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Court has repeatedly recognized that offenders convicted in this District of drug- or gang-
related crimes resulting in murder routinely receive sentences “within the thirty-year range.”
United States v. Carmichael, Crim. No. CCB-97-0329, 2023 WL 6809714, at *3 (D. Md. Oct. 16,
2023) (quoting United States v. Williams, Crim. No. CCB-07-402, 2021 WL 3725435, at *3 (D.
Md. Aug. 23, 2021)); United States v. Dawson, Crim. No. ELH-94-0010, 2024 WL 3455002, at
*13–*14 (D. Md. July 17, 2024). Accordingly, Mr. Bell’s sentence of 360 months, or thirty
years, falls squarely within the typical range imposed upon similarly situated defendants within
this District. Moreover, while Mr. Bell emphasizes that his sentence is longer than those of
similar defendants, including his co-defendants7 and other drug organization leaders who also
ordered retaliatory killings,8 Mr. Bell was more culpable compared to those defendants because
he orchestrated the murders in his case.
Finally, Mr. Bell argues that his rehabilitation while incarcerated warrants a sentence
reduction. While his rehabilitation is commendable,9 rehabilitation alone in the absence of
7 Mr. Spann, a co-defendant who participated in the contracted murder as the getaway driver, received a twenty-
year (240-month) sentence. Mr. Sterling, another co-defendant who participated in the contracted murder as a
driver and co-conspirator, received a twenty-two-year (264-month) sentence. While neither Mr. Spann, Mr.
Sterling, nor Mr. Bell played the role as the active shooter, Mr. Bell was more involved, and therefore more
culpable, than Mr. Spann or Mr. Sterling. Specifically, unlike his co-defendants, Mr. Bell led the drug
organization, contracted for the murders, and orchestrated the crimes.
8 Mr. Bell contends that his sentencing length is disparately long as compared to Raeshio and Howard Rice
(collectively, “the Rice brothers”), who were also leaders of a drug organization involved in violent and
nonviolent crime over the span of a decade. (ECF 565, at 14-16). See also United States v. Rice, [1:04-cr-00323-
JKB-3] (D. Md. Aug. 3, 2022) (Mem. Order), ECF No. 696; United States v. Rice, [1:04-cr-00323-JKB-4] (D. Md.
Oct. 25, 2022) (Mem. Order), ECF No. 699; Gov’t’s Opp’n to Mot. for Compassionate Release, United States v.
Hall, [1:04-cr-00323-JKB] (D. Md. Oct. 9, 2025), ECF No. 717. Mr. Bell’s argument falls short, however, given
the nonviolent character of the Rice brothers’ offense conduct, which resulted in the sentences Mr. Bell refers
to in his argument. By comparison, Mr. Bell’s offense conduct was violent in nature, resulting in the death of
Mr. Sterling. (ECF No. 200, Attach. A.)
9 In his Motion, Mr. Bell offers evidence of his rehabilitation through his steady employment, completion of
his General Education Development (GED) test, and participation in educational, therapeutic, and
rehabilitative courses. (ECF No. 565 at 18–19.) He also references his leadership and community involvement
as an active mentor for other inmates and at-risk youth. (Id.)
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additional factors is not sufficient to establish “extraordinary and compelling” circumstances.
28 U.S.C. § 994(t); Burleigh, 145 F.4th at 552 (acknowledging that rehabilitation alone is
insufficient as an “extraordinary and compelling” reason, and instead considering
rehabilitation alongside other factors, such as the nature and severity of the offense); United
States v. Millner; Crim. No. JKB-08-0086, 2024 WL 1678559 (D. Md. Apr. 18, 2024)
(emphasizing that rehabilitation efforts, even if commendable, are insufficient in the absence
of other “extraordinary and compelling” reasons). Accordingly, as explained above, Mr. Bell
has not established an “extraordinary and compelling” reason for relief, and he is ineligible for
compassionate release.
III. 3553(a) Factors
Failure to demonstrate an extraordinary and compelling reason for relief precludes
compassionate release. Nevertheless, for completeness, this Court briefly notes that Mr. Bell’s
requested relief is also inconsistent with the factors provided in 18 U.S.C. § 3553(a). In United
States v. McCoy, 981 F.3d 271 (4th Cir. 2020), the Fourth Circuit made clear that “not all
defendants . . . should receive new sentences,” and that “courts should be empowered to
relieve some defendants of those sentences on a case-by-case basis.” 981 F.3d at 286–87
(internal quotation marks omitted). Accordingly, a court must conduct an “individualized
assessment” under § 3553(a) to determine a defendant’s eligibility for a reduction. Id. at 286.
Pursuant to § 3553(a), this Court must consider: (1) the defendant’s personal history and
characteristics; (2) his sentence relative to the nature and seriousness of his offense; (3) the
need for a sentence to provide just punishment, promote respect for the law, reflect the
seriousness of the offense, deter crime, and protect the public; (4) the need for rehabilitative
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services; (5) the applicable guideline range; and (6) the need to avoid unwarranted sentencing
disparities among similarly situated defendants. 18 U.S.C. § 3553(a). On balance, these factors
also weigh against granting Mr. Bell’s Motion for Compassionate Release.
In conducting an individualized assessment of Mr. Bell and his case, the Court first
considers his personal history and characteristics. Mr. Bell’s arguments related to his youth at
the time of the offense and his traumatic childhood fit firmly within this factor. As to his youth
at the time of the offense, Mr. Bell cites to publications which, he states, demonstrate that
youthful defendants are “vulnerable to peer pressure,” “prone to impulsivity,” and “stimulus
seeking.” (ECF No. 565 at 12–13.) As explained above, however, Mr. Bell was not considered
a youth at the time of the instant offense. Moreover, even if his age at the time of the offense
did constitute youth status, the instant offenses were not impulsive but rather reflected a
deliberate plan to orchestrate several murders. (ECF No. 200, Attach. A); see United States v.
Brown, No. 2:11-cr-152, 2024 WL 3357836, at *6 (E.D. Va. July 10, 2024) (reasoning that a
“defendant’s deliberate, planned act in the instant offense . . . combined with his previous
criminal conduct, undermines the argument that his actions resulted primarily from youthful
impulsivity.”). As to personal history, a court may consider evidence of a difficult, traumatic
childhood under § 3553(a)(1) as a mitigating factor, but a traumatic childhood alone is
insufficient. See, e.g., United States v. Harris, Crim. No. SAG-05-0061, 2026 WL 318977, at *4
(D. Md. Feb. 6, 2026).
Although Mr. Bell received several disciplinary infractions early in his incarceration,
(ECF No. 560 at 11–12), he has made significant progress toward rehabilitation by completing
his General Education Development test, maintaining steady employment, and participating
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in therapeutic and rehabilitative courses. (Id.) Such efforts are commendable and weigh in
favor of relief. See, e.g., United States v. Martin, Crim. No. RDB-04-0029, 2021 WL 3172278, at
*3 (D. Md. July 27, 2021) (finding the defendant’s rehabilitative efforts, including his
participation in both educational and therapeutic courses, to weigh in favor of relief).
Nevertheless, the remaining § 3553(a) disfavor relief in this case. As an initial matter,
the need to deter recidivism and provide rehabilitative services, and the applicable guideline
range weigh against relief. Under these factors, a court may place significant weight on
criminal history, especially when there is a heightened concern of recidivism due to numerous
prior convictions. Compare United States v. Davis, 130 F.4th 114, 126–28 (4th Cir. 2025) (relying
significantly on the defendant’s extensive criminal history to justify sentence where he had
repeated incarceration and gang affiliations), and United States v. Morsley, Crim. No. RDB-08-
401, 2022 WL 1062020, at *4 (D. Md. Apr. 8, 2022) (considering the defendant’s lengthy
criminal history as part of the § 3553 analysis to weigh against relief), with United States v. Hegie,
Crim. No. RDB-14-411, 2022 WL 605383, at *3 (D. Md. Mar. 1, 2022) (acknowledging that a
defendant’s limited criminal history may weigh in favor of relief). In this case, Mr. Bell’s
history of criminal involvement is extensive, suggesting that a significant sentence is
appropriate to deter recidivism and protect the community. See (PSR ¶¶ 28–36 (listing six
prior convictions, including assault and drug-related charges)). Indeed, Mr. Bell’s prior
convictions resulted in his classification as a career offender at sentencing in this case.10 (Id.)
10 A defendant is a “career offender” if (1) the defendant was at least eighteen years old at the time of the instant
offense; (2) the instant offense is a felony that is either a “crime of violence” or a “controlled substance offense”;
and (3) the defendant has at least two prior felony convictions for either a “crime of violence” or a “controlled
substance offense.” U.S.S.G. § 4B1.1(a).
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Furthermore, Mr. Bell’s sentence of 360 months, already within the Sentencing
Guidelines range and agreed upon by both parties in the plea agreement, reflects the nature
and circumstances of both his direct involvement in multiple contracted killings and a long
history of criminal activity. See United States v. Bond, 56 F.4th 381, 384–85 (4th Cir. 2023)
(explaining that in weighing § 3553(a) factors, courts should avoid changing a plea agreement’s
terms absent compelling circumstances, particularly when the exact sentence negotiated in the
agreement is imposed). His instant offense was serious and violent in nature—the uncontested
facts indicate that he planned and executed a murder-for-hire conspiracy in connection with
organized crime, (ECF No. 200, Attach. A)—which weighs against relief. See Morsley, 2022 WL
1062020, at *4 (finding that the serious and violent nature of the defendant’s offenses, which
included participating in armed robberies, weighed against relief). Finally, there is no evidence
that Mr. Bell’s sentence reflects an unwarranted sentencing disparity. As explained above, this
Court generally imposes sentences of approximately thirty years for similarly situated
defendants. See, e.g., Carmichael, 2023 WL 6809714, at *3. Mr. Bell received a 360-month
sentence, which is on par with sentences applied to similar defendants who held leadership
roles in similar crimes. See (ECF No. 200.) Accordingly, the nature and circumstances of the
offense, the applicable guideline range, and the need to avoid sentencing disparities each
disfavor relief. On balance, therefore, the § 3553(a) factors weigh against relief in this case.
For these reasons, Mr. Bell’s Motion for Compassionate Release (ECF No. 560, 565) is
DENIED.
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CONCLUSION
For the reasons stated above, it is hereby ORDERED this 4th day of March 2026 that
Defendant’s Motion for Compassionate Release (ECF Nos. 560, 565) is DENIED.
A separate Order follows.
Richard D. Bennett
United States Senior District Judge
/s/
Case 1:06-cr-00179-RDB Document 573 Filed 03/04/26 Page 15 of 15