USA v. Thomas

1
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
vs. ) Case No. 4:20-cr-00825- MTS
)
SAMUEL THOMAS )
)
Defendant. )
MEMORANDUM AND ORDER
Defendant Samuel Thomas has filed a Motion for Order Reducing Sentence or Modifying
Judgment pursuant to 18 U.S.C. § 3582(c)(1)(A). Doc. [153]. Because Defendant has failed to
demonstrate that he has exhausted administrative remedies and the Government properly raised
the issue, the Court will deny the Motion without prejudice.
I. Background
On May 16, 2023, Defendant Samuel Thomas was sentenced to 72 months of incarceration
and four years of supervised release pursuant to a guilty plea for Possession with Intent to
Distribute Fentanyl, in violation of 21 U.S.C. § 841(a)(1). Doc. [142]. Defendant is currently
serving his sentence at Memphis FCI and has a release date of September 8, 2028.1 Defendant
seeks a sentence reduction pursuant to 18 U.S.C. § 3582(c)(1)(A).
Defendant claims that his family circumstances present extraordinary and compelling
reasons warranting a reduction in his sentence. See Doc. [149-1] at 2. Specifically, Defendant
references three conditions relevant to this determination: his wife’s alcohol consumption and
1 https://www.bop.gov/inmateloc/ (last visited January 23, 2026).
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mental health crises; his mother’s 2016 diagnoses of thyroid cancer, breast cancer, and 2023 brain
aneurism; and his father’s diabetes and high blood pressure. Id.
II. Legal Standard
Under § 3582(c)(1)(A), compassionate relief may be granted if the court finds, after
considering the applicable factors in 18 U.S.C. § 3553(a),2 an extraordinary and compelling reason
warranting such a reduction. U.S.S.G. § 1B1.13(a)(1)(A). Additionally, a defendant must
demonstrate that he is no longer a danger to the safety of any other person or to the community.
U.S.S.G. § 1B1.13(a)(2).3 The defendant bears the burden of establishing that such relief is
warranted, as compassionate release is an “extraordinary and rare event.” United States v. Jones,
836 F.3d 896, 899 (8th Cir. 2016). However, a Defendant must first exhaust their administrative
remedies.
“According to the plain terms of § 3582(c)(1)(A), prisoners can bring compassionate-
release motions on their own once they have exhausted administrative remedies.” United States v.
Houck, 2 F.4th 1082, 1084 (8th Cir. 2021). The administrative remedies exhaustion required under
18 U.S.C. § 3582 is a “mandatory claim-processing rule.” Id. A mandatory claim-processing rule
“must be enforced so long as the opposing party properly raises it.” Id. When failure of
administrative exhaustion is properly raised by the Government, this Court must dismiss a
compassionate-release motion without prejudice. Id. Under § 3582(c)(1)(A), exhaustion occurs at
the earlier of: 1) after the defendant has fully exhausted all administrative rights to appeal a failure
2 The factors include, among other things: “(1) the nature and circumstances of the offense and the history and
characteristics of the defendant,” as well as “(2) the need for the sentence imposed- (A) to reflect the seriousness of
the offense, to promote respect for the law, and to provide punishment for the offense; (B) to afford adequate
deterrence to criminal conduct; [and] (C) to protect the public from further crimes of the defendant.” 18 U.S.C. §
3553(a).
3 Relevant factors include the nature of the offense, the history and characteristics of the defendant, and the nature of
the danger. Id. (incorporating 18 U.S.C. § 3142(g)).
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of the Bureau of Prisons to bring a motion on the defendant’s behalf, or 2) the lapse of 30 days
from the receipt of such a request by the warden of the defendant’s facility.
III. Discussion
The Government argues that the Court should deny Defendant’s Motion for multiple
reasons. See Doc. [151] at 4-6. However, because the Government properly raised Defendant’s
failure to exhaust and Defendant has made no showing that he has exhausted administrative
remedies, the Court will deny Defendant’s Motion without prejudice. Houck, 2 F.4th at 1084; see
also United States v. Cotton, 4:21-cr-00387-SRC-1, 2025 WL 1809795, *4–5. (E.D. Mo. July 1,
2025) (dismissing defendant’s compassionate release motion without prejudice because
government properly raised failure to exhaust, and defendant did not provide evidence that he had
exhausted administrative remedies).
IV. Conclusion
For the reasons set forth above, the Court denies without prejudice Defendant’s Motion
because Defendant has failed to make a showing that he exhausted his administrative remedies
under 18 U.S.C. § 3582(c)(1)(A). Accordingly,
IT IS HEREBY ORDERED that Defendant’s Motion for Order Reducing Sentence or
Modifying Judgment pursuant to 18 U.S.C. § 3582(c)(1)(A), Doc. [153], is DENIED WITHOUT
PREJUDICE.
Dated this 23rd day of 2026
________________________________
MATTHEW T. SCHELP
UNITED STATES DISTRICT JUDGE
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