USA v. Reed

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
UNITED STATES OF AMERICA CRIMINAL ACTION
VERSUS
QUINN P. REED 16-51-SDD-RLB

ORDER
This matter is before the Court on a Motion for Sentence Reduction Pursuant to 18 U.S.C.
§ 3582(c) filed by Defendant Quinn Reed (“Defendant”).
1
The Government opposes this motion
in the form of a Motion to Dismiss.
2
For the following reasons, the Defendant’s motion is denied
for lack of jurisdiction.
The Government asserts that the Defendant has failed to exhaust his administrative
remedies. As such, the threshold issue is whether the Court has authority to consider the
Defendant’s motion.
The compassionate release statute states in pertinent part:
The court may not modify a term of imprisonment once it has been imposed
except that ... the court, upon motion of the Director of the Bureau of Prisons, or
upon motion of the defendant after the defendant 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, may reduce the
term of imprisonment (and may impose a term of probation or supervised release
with or without conditions that does not exceed the unserved portion of the
original term of imprisonment), after considering the factors set forth in section
3553(a) to the extent that they are applicable, if it finds that ... extraordinary and
compelling reasons warrant such a reduction .... 18 U.S.C. § 3582(c)(1)(A)(i).

1
R. Doc. 129.
2
R. Doc. 132.
Case 3:16-cr-00051-SDD-RLB Document 143 08/14/26 Page 1 of 2

CHIEF JUDGE SHELLY D. DICK
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA
The statute therefore provides two routes whereby a defendant's motion can be brought
properly before the court. Both routes begin with the defendant requesting that “the Bureau of
Prisons” “bring a motion on the defendant's behalf.” Id.
As clarified by the Court in United States v. Franco, No. 20-60473, 2020 WL 5249369,
at *1 (5th Cir. Sept. 3, 2020), the statute's language is mandatory. Congress has commanded that
a “court may not modify a term of imprisonment” if a defendant has not filed a request with the
BOP. See 18 U.S.C.§ 3582(c) (emphasis added).
Here, the Defendant does not allege that he submitted a request to the Bureau of Prisons
to bring a motion for compassionate relief on his behalf. As such, it does not appear that the
Defendant fully exhausted all administrative rights as required by 18 U.S.C. § 3582(c)(1)(A).
Accordingly,
IT IS ORDERED that the Government’s Motion to Dismiss (R. Doc. 132) is
GRANTED and Defendant’s motion for compassionate release (R. Doc. 129) is DENIED
WITHOUT PREJUDICE for lack of jurisdiction, subject to refiling if Defendant exhausts his
administrative remedies as required by 18 U.S.C. § 3582(c)(1)(A)
3
.
Signed in Baton Rouge, Louisiana, on August 14, 2026.

3
Even if Defendant had exhausted his administrative remedies his motion would still fail on the merits. His allegations
about not receiving proper treatment for deep vein thrombosis do not present an extraordinary and compelling
circumstance that would justify release. See United States v. Applewhite, 2026 WL 2225654 (E.D. N.Y. Aug. 3, 2026
(general allegations of inadequate medical care for DVT and other illnesses do not rise to the level of an extraordinary
and compelling reason justifying release); and United States v. Williams, 161 F.4th 951, 953 (6th Cir. 2025) (alleged
inadequate treatment for thrombophilia and DVT does not constitute extraordinary and compelling circumstances
justifying release). Further, it appears the Defendant is receiving adequate outside treatment at Duke Vascular
Specialists of Raleigh at the Duke University School of Medicine. See R. Doc. 139-3.
S
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