USA v. Vasquez

1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW MEXICO
____________________
UNITED STATES OF AMERICA,
Plaintiff,
v. Case No.: 1:16-cr-002700-JCH
CARLOS VASQUEZ,
Defendant.
MEMORANDUM OPINION AND ORDER
DENYING DEFENDANT’S MOTION AS MOOT
Defendant Carlos Vasquez sought compassionate release pursuant to 18 U.S.C. § 3582.
See generally Doc. 123 (“Motion”); see 18 U.S.C. § 3582(b)(1) (authorizing modification of a
defendant’s sentence of imprisonment under 18 U.S.C. § 3582(c)). At the time of filing, was in
custody following the revocation of his term of supervision, pursuant to the judgment and sentence
issued on April 1, 2025. Doc. 116 at 1. Therein, the Court ordered Vasquez “be imprisoned for a
total term of: 8 months or until bed space becomes available at an inpatient treatment program;
whichever occurs first.” Id. at 2. The import of the sentence was simple: release Vasquez to an
inpatient treatment program once a bed was available, provided that happened before the eight-
month term of imprisonment expired. He was not released, despite a bed opening at the New
Mexico Wellness Treatment Program in Taos, New Mexico. See Doc. 119 at 2 (detailing why the
Federal Bureau of Prisons purportedly could not release him). Consequently, Vasquez filed the
Motion.
Vasquez requested a time-served sentence and an order of release so he could complete his
term of supervised release at the treatment program. Doc. 123 at 1. The Government opposed.
Case 1:16-cr-02700-JCH Document 127 Filed 04/07/26 Page 1 of 2

2
See generally Doc. 124. Vasquez did not file a reply. Instead, he finished his eight-month term of
incarceration, was released on October 22, 2025, and recommenced his supervision. Doc. 125 at 1.
Once a “defendant’s prison sentence has expired, a challenge to [their] conviction is moot
unless there is an ongoing collateral consequence of the conviction, that can be redressed by a
favorable judicial decision.” United States v. Fields, 823 F. App’x 587, 589 (10th Cir. 2020)
(citation modified). In other words, a court lacks jurisdiction “because [the defendant’s] release
from prison rendered his . . . motion for sentence reduction moot.” Id. at 591.
Though Fields analyzed a defendant’s request under Section 3582(c)(1)(B)—providing for
a sentence reduction under the First Step Act—rather than Section 3582(c)(1)(A)—regarding
compassionate release—the rationale holds true. See, e.g., United States v. Chavez, No. 12-CR-
2519, 2022 WL 1651105, at *1 (D.N.M. May 24, 2022) (applying this rationale); United States v.
Carr, No. 16-cr-054, 2021 WL 5565804, at *3 (D. Colo. Nov. 29, 2021) (“Defendant’s release to
home confinement renders her proffered basis for compassionate release moot.”).
Here, given that Vasquez is no longer in custody with the Bureau of Prisons and is on
supervised release, the Court cannot redress his incarceration. Therefore, the Court hereby denies
Vasquez’s Motion, Doc. 123, as moot. Vasquez’s prior emergency motion for release, Doc. 119,
is similarly denied as moot.
It is so ordered.
________________________________________
SENIOR UNITED STATES DISTRICT JUDGE
Case 1:16-cr-02700-JCH Document 127 Filed 04/07/26 Page 2 of 2