USA v. Ortiz-Alcantara et al

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
UNITED STATES OF AMERICA,
v.
ESTARLIN ORTIZ-ALCANTARA,
Defendant.
*
*
*
*
*
*
*
*
*
*
Criminal Action No. 22-cr-10211-ADB
MEMORANDUM AND ORDER ON DEFENDANT’S
MOTION FOR REDUCTION OF SENTENCE
BURROUGHS, D.J.
Currently before the Court is Estarlin Ortiz-Alcantara’s (“Ortiz-Alcantara”) motion for
reduction of sentence pursuant to 18 U.S.C. § 3582. [ECF No. 474]. For the reasons set forth
below, the motion is DENIED.
I. 	FACTUAL BACKGROUND
On December 14, 2024, Ortiz-Alcantara pled guilty to drug trafficking offenses involving
the possession and distribution of fentanyl. At sentencing, based on the quantity of fentanyl
attributable to him, the Court determined that with an adjusted offense level of 38 in criminal
history category I, he was subject to a mandatory 10 year sentence and his advisory guideline
sentencing range was 235 to 293 months. [ECF No. 468]. The Court sentenced him to 120
months.
Ortiz-Alcantara now seeks a reduction in his sentence and cites several reasons in support,
which include the following: (1) his rehabilitative accomplishments, (2) sentencing disparities
among similarly situated individuals, and (3) 3553(a) factors. [ECF No. 474]. None of these
Case 1:22-cr-10211-ADB Document 476 Filed 01/13/26 Page 1 of 6

2
circumstances considered alone or in combination warrants his release and the motion is
therefore denied.
II. 	PROCEDURAL BACKGROUND
On October 14, 2025, he filed the instant motion, asking the Court to reduce his sentence.
[ECF No. 474]. The Government opposed the motion on November 6, 2025. [ECF No. 475].
III. 	DISCUSSION
Ortiz-Alcantara seeks release under 18 U.S.C. § 3582(c)(1)(A). See [ECF No. 474 at 1].
Previously, incarcerated defendants could seek release under this statute only upon motion of the
BOP. The First Step Act of 2018, however, amended that provision to allow prisoners to seek
relief directly from the courts once they have exhausted their administrative remedies. Section
3582(c)(1)(A) now provides that
[t]he Court may not modify a term of imprisonment once it has been imposed
except that . . . in any case . . . the [C]ourt, 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 . . . after considering the factors set forth in [18
U.S.C. §] 3553(a) to the extent that they are applicable, if it finds that . . .
(i) extraordinary and compelling reasons warrant such a reduction . . . and that
such a reduction is consistent with applicable policy statements issued by the
Sentencing Commission . . . .
18 U.S.C. § 3582(c)(1)(A) (emphasis added).
Section 1B1.13 of the Sentencing Guidelines further explains that the Court may reduce a
defendant’s sentence if, after considering the factors in 18 U.S.C. § 3553(a), the Court
determines that
(1)(A) extraordinary and compelling reasons warrant the reduction; . . .
(2) the defendant is not a danger to the safety of any other person or to the
community, . . . ; and
(3) the reduction is consistent with this policy statement.
Case 1:22-cr-10211-ADB Document 476 Filed 01/13/26 Page 2 of 6

3
U.S.S.G. § 1B1.13.
To begin, Ortiz-Alcantara makes no representations regarding whether he has exhausted
his administrative remedies. As the Government notes, the defendant bears the burden of
establishing exhaustion. [ECF No. 475 at 3 n.2]. The Defendant’s failure here to meet that
burden is itself grounds to deny this motion. See United States v. Cruz-Rivera, No. 15-cr-00486,
2025 WL 2640793, at *3 (D.P.R. Sept. 15, 2025) (“[Defendant] has the burden of showing that
he exhausted administrative remedies prior to bringing [a compassionate release] claim before
the Court.”); cf. United States v. Portway, 506 F. Supp. 3d 102, 103 (D. Mass. 2020) (requiring
that the defendant exhaust his administrative remedies before the court “may reach the merits of
his petition for compassionate release.”). Assuming for the sake of argument that Ortiz-
Alcantara did in fact exhaust, the Court will reach the merits of his petition.
As with exhaustion, Ortiz-Alcantara bears the burden of proving that he is entitled to
relief under 18 U.S.C. § 3582. United States v. Butler, 970 F.2d 1017, 1026 (2d Cir. 1992) (“If
the defendant seeks decreased punishment, he or she has the burden of showing that the
circumstances warrant that decrease.”). To meet this burden, he must satisfy three requirements.
See United States v. Jackson, No. 19-cr-00347, 2020 WL 3402391, at *4 (D.D.C. June 19,
2020). First, he must show that “extraordinary and compelling reasons” warrant his release;
second, he must show that release is consistent with the Sentencing Commission’s policy, which
Case 1:22-cr-10211-ADB Document 476 Filed 01/13/26 Page 3 of 6

4
requires showing that he is not a danger to the safety of any other person or the community;
finally, he must show that the sentencing factors in 18 U.S.C. § 3553(a) justify release. Id.
Thus, the Court must now determine whether “extraordinary and compelling reasons”
support compassionate release, consistent with the § 3553(a) sentencing factors and the
Sentencing Commission’s policy. 18 U.S.C. § 3582(c)(1)(A).
A. 	“Extraordinary and Compelling Reasons” Under 18 U.S.C. § 3582(c)(1)(A)
The Sentencing Guidelines recognize that compassionate release due to extraordinary and
compelling reasons may be appropriate in cases where, for example, family circumstances or the
defendant’s age or health make release appropriate. U.S.S.G. § 1B1.13 cmt. n.1(A)–(C). Courts
have found that the Sentencing Guidelines set forth a non-exhaustive list and that release may
also be warranted under the policy’s “catch-all provision [which] allows for compassionate
release when ‘there exists in the defendant’s case an extraordinary and compelling reason other
than, or in combination with’ the other enumerated reasons.” United States v. Guzman-Soto, No.
18-cr-10086, 2020 WL 2104787, at *3 (D. Mass. May 1, 2020) (quoting U.S.S.G. § 1B1.13 cmt.
n.1(D)).
Ortiz-Alcantara relies heavily on his rehabilitative efforts as warranting a sentence
reduction. The Court is impressed with the rehabilitative efforts that have been made by Ortiz-
Alcantara and encourages him to continue on that path, but such efforts alone do not constitute
the “extraordinary” or “compelling” circumstances that warrant a sentence reduction. The Court
also notes that the Defendant’s early steps regarding rehabilitation were already taken into
account at his sentencing. [ECF No. 468 at 11].
Ortiz-Alcantara also asserts that he should receive a sentence reduction based on
sentencing disparities between him and his co-defendants as well as between him and defendants
in other cases. This argument carries virtually no weight. The defendant was the leader of a
Case 1:22-cr-10211-ADB Document 476 Filed 01/13/26 Page 4 of 6

5
large drug trafficking organization and received the statutorily mandated sentence, which was
roughly half of what the sentencing guidelines suggested was the appropriate sentence.
Thus, the Court finds that Ortiz-Alcantara has failed to meet his burden of demonstrating
“extraordinary and compelling reasons” that would justify his early release.
B. 	Dangerousness and the § 3553(a) Factors
Although Ortiz-Alcantara has failed to meet his initial burden, in the interest of a
complete record, the Court will briefly address the other factors.
First, the Court must consider whether Ortiz-Alcantara is “a danger to the safety of any
other person or to the community.” U.S.S.G. § 1B1.13(2). Here, given Ortiz-Alcantara’s
personal history and his leadership role in a significant drug trafficking organization (and despite
his laudable post-conviction rehabilitative efforts), the Court cannot conclude that if released, he
would not pose a danger to the safety of the community.
Second, the Court must “consider[] the factors set forth in section 3553(a),” 18 U.S.C.
§ 3582(c)(1)(A), including:
(1) 	the 	nature 	and 	circumstances 	of 	the 	offense 	and 	the 	history 	and
characteristics of the defendant;
(2) 	the need for the sentence imposed—
(A) to reflect the seriousness of the offense, to promote respect for the law, and
to provide just punishment for the offense;
(B) to afford adequate deterrence to criminal conduct;
(C) to protect the public from further crimes of the defendant; and
(D) to provide the defendant with needed educational or vocational training,
medical care, or other correctional treatment in the most effective manner;
. . .
(4) the kinds of sentence and the sentencing range established [under the applicable
Guidelines sections]
. . . [and]
(6) the need to avoid unwarranted sentencing disparities among defendants with
similar records who have been found guilty of similar conduct.
18 U.S.C. § 3553(a). The Court weighs these factors against the reasons favoring Ortiz-
Alcantara’s immediate release. United States v. Ebbers, 432 F. Supp. 3d 421, 430–31 (S.D.N.Y.
Case 1:22-cr-10211-ADB Document 476 Filed 01/13/26 Page 5 of 6

6
2020) (“[I]n considering the section 3553(a) factors, [the court] should assess whether those
factors outweigh the ‘extraordinary and compelling reasons’ warranting compassionate release,
particularly whether compassionate release would undermine the goals of the original
sentence.”).
Releasing Ortiz-Alcantara early, given his reasons stated in support, would be
inconsistent with the purposes of sentencing including punishment and deterrence. 	In reaching
this conclusion, the Court notes that Ortiz-Alcantara was sentenced to 120 months incarceration
which, again, was a generous sentence given the nature and circumstances of his offenses and
when measured against the advisory guideline sentencing range. The Defendant has served well
under half of the sentence imposed. Even assuming that a sentence reduction could theoretically
be appropriate at some point, none of the section 3553(a) factors support such a reduction here
when the defendant has served only a small percentage of his sentence.
IV. 	CONCLUSION
The Court finds that Ortiz-Alcantara has failed to meet his burden of demonstrating that
compassionate release or a sentence reduction is justified. His recourse remains with the Warden
and then perhaps another motion when he has served a greater percentage of his sentence.
Accordingly, Ortiz-Alcantara’s motion for a sentence reduction, [ECF No. 474], is DENIED.
SO ORDERED.
January 13, 2026 	/s/ Allison D. Burroughs
ALLISON D. BURROUGHS
U.S. DISTRICT JUDGE
Case 1:22-cr-10211-ADB Document 476 Filed 01/13/26 Page 6 of 6