USA v. Dickson et al

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
UNITED STATES OF AMERICA, 	§
§
v. 	§ 	CRIMINAL NO. 3:20-CR-0250-B-1
§
ERIC DICKSON, 	§
§
Defendant. 	§
MEMORANDUM OPINION AND ORDER
Before the Court is Defendant Eric Dickson’s Motion to Reduce Sentence (Doc. 119). For
the following reasons, Dickson’s Motion is DENIED WITHOUT PREJUDICE.
I.
BACKGROUND
The Court sentenced Dickson to 120 months of imprisonment and three years of supervised
release after he pleaded guilty to possession of a firearm by a convicted felon. Doc. 90, J., 1-3.
Dickson, now 41 years old, is serving his sentence at El Reno Federal Correctional Institution. His
scheduled release date is November 30, 2028.1
Dickson filed a motion seeking compassionate release under 18 U.S.C. § 3582(c)(1)(A). 2
Doc. 119, Mot. Sent. Reduc., 1. He argues that recent changes in the law warrants compassionate
release. See id. at 1-2. The Court considers the Motion below.
1 The Court derives this information from the Bureau of Prisons (BOP)’s Inmate Locator, available at
https://www.bop.gov/inmateloc.
2 While Dickson does not identify § 3582(c)(1)(A) by name, he twice references “compassionate release” in
his sentence reduction request, so the Court construes Dickson’s motion as one brought under §
3582(c)(1)(A). See Doc. 119, Mot. Sent. Reduc., 1-2.
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II.
LEGAL STANDARD
Under § 3582(c)(1)(A), as amended by the First Step Act of 2018, “[a] court, on a motion by
the [Bureau of Prisons (“BOP”)] or by the defendant after exhausting all BOP remedies, may reduce
or modify a term of imprisonment, probation, or supervised release after considering the factors of
18 U.S.C. § 3553(a), if ‘extraordinary and compelling reasons warrant such a reduction.’” United
States v. Chambliss, 948 F.3d 691, 692-93 (5th Cir. 2020) (footnote omitted) (quoting 18 U.S.C. §
3582(c)(1)(A)(i)).
III.
ANALYSIS
The Court denies Dickson’s motion for compassionate release because he has not shown
“extraordinary and compelling reasons” warranting compassionate release under § 3582(c)(1)(A)(i).
The 	section 	does 	not 	define 	the 	“extraordinary 	and 	compelling 	reasons” that 	may 	merit
compassionate release. See United States v. Shkambi, 993 F.3d 388, 391 (5th Cir. 2021). Rather,
Congress “delegated that authority to the Sentencing Commission,” which was directed to
“promulgate general policy statements regarding the sentencing modification provisions in §
3582(c)(1)(A) that describe what should be considered extraordinary and compelling reasons for
sentence reduction, including the criteria to be applied and a list of specific examples.” Id. (citation
modified) (citing 28 U.S.C. § 994(t)).
To outline the types of reasons that the BOP or a court may consider “extraordinary and
compelling,” the Commission issued a policy statement—section 1B1.13 of the U.S. Sentencing
Guidelines Manual (the “Sentencing Guidelines”). As amended in 2023, the statement “identifies
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six categories of circumstances that may qualify as “‘extraordinary and compelling.’” United States v.
Bravo-Escalera, No. 4:19-CR-00285-ALM-AGD, 2025 WL 1668212, at *2 (E.D. Tex. June 12, 2025)
(citing U.S. SENT’ G GUIDELINES M ANUAL § 1B1.13(b) (U.S. SENT’G C OMM ’N 2023). Those
categories include “(1) the medical circumstances of the defendant; (2) the age of the defendant; (3)
the family circumstances of the defendant; (4) whether the defendant was a victim of abuse while in
custody; (5) other reasons similar in gravity to those previously described; and (6) an unusually long
sentence.” Id.
Although those categories are broadly stated, the Fifth Circuit recently confirmed that a
“prisoner may not leverage non-retroactive changes in criminal law to support a compassionate release
motion, because such changes are neither extraordinary nor compelling.” United States v. Austin, 125
F.4th 688, 692 (5th Cir. 2025) (citation omitted and emphasis added). However, even non-
retroactive changes to the law may be considered solely in determining the extent of a sentence
reduction where the defendant establishes a separate “extraordinary and compelling” reason for the
reduction. § 1B1.13(c).
Dickson does not identify which of the six categories of “extraordinary and compelling
reasons” applies here. Instead, Dickson contends that a 2024 amendment to section 5H.1 of the
Sentencing Guidelines warrants compassionate release. See Doc. 119, Mot. Sent. Reduc., 1-2. The
amendment in question—Amendment 829—expanded sentencing courts’ options to depart from the
recommended sentencing range in consideration of a defendant’s young age at the time of an
offense. See U.S. SENT’G GUIDELINES M ANUAL App. C, amend. 829 (U.S. SENT’G COMM ’N 2024).
But as Dickson acknowledges, the amendment did not apply retroactively, see id. at 1, thus it cannot
“support a compassionate release motion.” See Austin, 125 F.4th at 692. Dickson does not assert any
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separate reason for a sentence reduction that would allow the Court to consider the non-retroactive
change to determine the extent of reduction under section 1B1.13(c). Finally, section 5H1.1 has
since been deleted in its entirety—along with other departure provisions of the guidelines—effective
November 1, 2025. See U.S. SENT’G GUIDELINES M ANUAL App. C, amend. 836 (U.S. SENT’G
COMM ’N 2025). As section 5H1.1 is no longer in effect, its prior amendment cannot create an
extraordinary and compelling reason for reduction of sentence.
Dickson has not demonstrated how his personal circumstances rise to the level of
extraordinary and compelling as necessary to warrant compassionate release. Given these threshold
obstacles, the Court need not consider the sentencing factors set forth in 18 U.S.C. § 3553(a).
IV.
CONCLUSION
Dickson’s Motion to Reduce Sentence fails because he has not demonstrated extraordinary
and compelling reasons for compassionate release. For this reason, the Court DENIES Dickson’s
Motion (Doc. 119) WITHOUT PREJUDICE.
By denying Dickson’s Motion without prejudice, the Court permits Dickson to file a
subsequent motion seeking compassionate release in the event he demonstrates: (1) a change in
circumstances rising to the level of extraordinary and compelling; (2) that he satisfied the exhaustion
requirement with respect to those circumstances; and (3) that the § 3553(a) sentencing factors
support his release.
SO ORDERED.
SIGNED: March 31, 2026.
JANE J. BOYLE
SENIOR UNITED STATES DISTRICT JUDGE
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