The United States Court of Appeals for the Fourth Circuit held that the U.S. District Court for the Eastern District of Virginia did not abuse its discretion in granting the defendant’s motion for compassionate release based on sentencing disparities alone between the defendant and his co-defendants because those disparities constituted extraordinary and compelling reasons under 18 U.S.C. § 3582(c)(1)(A). The Court affirmed the District Court’s order, emphasizing that the vast differences in sentences—particularly given the defendant’s exercise of his jury trial right and the jury’s findings of mitigating circumstances—fell within the District Court’s broad discretion to identify “other reasons” similar in gravity to those outlined in U.S.S.G. § 1B1.13(b).

Background

During the 1990s, Shaheem Johnson participated in a multi-state drug-trafficking enterprise, during which he was directly responsible for the deaths of two individuals. In one incident, Johnson, along with Damein Piranti, Rickey Piranti, and another co-conspirator, shot and killed Bernard Franklin. In a separate incident, Johnson and a co-conspirator hired hit man Eldon Brown to kill Richard Villa. Johnson was arrested in August 1997 in connection with the drug-trafficking enterprise.

Johnson, Damein Piranti, and Rickey Piranti were charged with murder in aid of racketeering under 18 U.S.C. § 1959(a)(1) in connection with Franklin’s death. Johnson was additionally charged under §§ 1959(a)(1) and (2), as well as 18 U.S.C. §§ 924(c) and 924(j), in connection with Villa’s death. Rickey Piranti faced an additional § 1959(a)(1) charge for the murder of another individual.

Johnson proceeded to a jury trial. The jury convicted him of voluntary manslaughter of Franklin using a firearm during a drug-trafficking offense, in violation of §§ 924(c)(1) and 924(j), and aiding and abetting the murder of Villa in aid of racketeering, in violation of §§ 1959(a)(1) and (2). The jury’s special verdict form included findings that Johnson did not substantially plan or premeditate Villa’s killing, did not procure payment to Brown for it, and that Brown was the actual killer. Johnson was sentenced to two terms of life imprisonment plus 790 months in prison. His convictions were affirmed on direct appeal. 

Damein Piranti and Rickey Piranti pleaded guilty and cooperated with the Government. Damein pleaded guilty to his § 1959(a)(1) charge related to the Franklin killing and initially received a mandatory life sentence, which was later reduced to 20 years’ imprisonment; he was released in 2015. Rickey pleaded guilty to both of his § 1959(a)(1) charges and initially received two concurrent mandatory life sentences, which were reduced to 40 years’ imprisonment; he is scheduled to be released in 2032.

Eldon Brown was arrested in New York and indicted in December 1997 on various charges. He testified against Johnson, pleaded guilty to conspiracy to commit murder for hire, murder for hire, three counts of using a firearm during and in relation to a crime of violence, two counts of Hobbs Act robbery, and one count of making false statements. Brown was sentenced to five years’ imprisonment and was released in 2003.

In March 2021, Johnson filed a pro se motion for compassionate release under § 3582(c)(1)(A), which the Government opposed. In August 2021, counsel for Johnson filed a supplemental memorandum arguing, among other things, that sentencing disparities with Damein Piranti, Rickey Piranti, and Eldon Brown constituted extraordinary and compelling reasons for a sentence reduction. 

In August 2023, the District Court granted the motion in part, reducing Johnson’s sentence to 35 years’ imprisonment. The District Court determined that the sentence disparities weighed in favor of relief, noting that Damein and Rickey received 20 and 40 years, respectively, after pleading guilty to one and two § 1959(a)(1) murders, while Johnson was convicted of one such murder and sentenced to life, despite the jury findings of mitigating circumstances and his minor participation. The District Court found an even greater disparity with Brown, who served five years, given Brown’s role as the actual killer and Johnson’s aiding and abetting conviction. The Government timely appealed.

Analysis

The Court began its analysis by outlining the framework for compassionate release motions. Under § 3582(c)(1)(A), a District Court may reduce a sentence if it finds that extraordinary and compelling reasons warrant the reduction and that the reduction is consistent with applicable policy statements issued by the Sentencing Commission. United States v. McCoy, 981 F.3d 271 (4th Cir. 2020). In the absence of an applicable policy statement, District Courts are empowered to consider any extraordinary and compelling reason for release that a defendant might raise. Id. The Court emphasized that this authority includes “any extraordinary and compelling reason.”

The Court next explained the deferential standard of review applicable to such decisions. It reviews a District Court’s ruling on a compassionate release motion for abuse of discretion. United States v. Davis, 99 F.4th 647 (4th Cir. 2024). A District Court abuses its discretion when it acts arbitrarily or irrationally, fails to follow statutory requirements, fails to consider judicially recognized factors, relies on erroneous factual or legal premises, or commits an error of law. United States v. Centeno-Morales, 90 F.4th 274 (4th Cir. 2024) (quoting United States v. Bethea, 54 F.4th 826 (4th Cir. 2022)). The reviewing court may not substitute its judgment for that of the district court. Bethea. 

Applying this standard, the Court determined that the District Court did not abuse its discretion in finding that sentencing disparities between Johnson and those of Damein Piranti, Rickey Piranti, and Eldon Brown weighed in favor of granting relief. The Court observed that Damein and Rickey effectively received 20 years for the § 1959(a)(1) conviction related to the Franklin killing, while Johnson received a life sentence for the same killing. The only difference, the Court noted, was that Johnson elected to exercise his right to a jury trial. Although Damein and Rickey cooperated with the Government, the District Court did not abuse its discretion in concluding that such cooperation, without more, did not justify the vast disparity in sentences.

The Court further reasoned that an even greater disparity existed between Johnson and Brown. At best, Brown served five years for the killing of Villa, and at worst, he served no time related to it. This stood in stark contrast to Johnson’s mandatory life sentence for the same killing. The Court concluded that the District Court was entitled to consider this disparity, particularly in light of the jury’s findings that Johnson was not the trigger man, did not substantially plan or premeditate the killing, and did not procure payment to Brown. 

It was not an abuse of discretion for the District Court to rely on the fact that one individual received a life sentence while another received possibly five years for the same killing, merely because the latter assisted the Government, the Court concluded. Additionally, the ambiguity surrounding Brown’s charges did not alter the calculus because District Courts exercise wide discretion in the sources and types of evidence used to determine appropriate sentences. Concepcion v. United States, 597 U.S. 481 (2022).

In elaborating on the scope of “extraordinary and compelling reasons,” the Court referenced U.S.S.G. § 1B1.13(b), which permits consideration of various circumstances and allows District Courts to contemplate “other reasons” that are similar in gravity. § 1B1.13(b)(5). Such reasons may stand alone or in combination with others, and there is no exhaustive list. The Court thus affirmed that it was within the District Court’s discretion to identify Johnson’s sentencing disparities as an “other reason” constituting an extraordinary and compelling factor. The Court noted that no binding precedent in the Fourth Circuit holds that a sentencing disparity alone cannot suffice for compassionate release.

The Court addressed arguments that the disparities were justified by cooperation, but it emphasized that whether reasonable minds could differ is not the standard for reversal. Rather, abuse of discretion is required, and none was present here. It highlighted the policy rationale implicit in § 3582(c)(1)(A) and McCoy, which empowers District Courts to address post-sentencing inequities, including those arising from trial penalties or disparate outcomes among similarly situated defendants, to promote fairness and avoid unwarranted disparities under 18 U.S.C. § 3553(a). 

By finding the disparities vast and significant—especially given the jury’s mitigating findings—the District Court reasonably applied this framework without relying on erroneous premises. The Court declined to address whether other factors considered by the District Court also supported relief, as the disparities alone were sufficient to uphold the ruling. The Court commented that this approach underscores the broad latitude afforded District Courts in compassionate release determinations, reinforcing doctrinal flexibility in the wake of the First Step Act to rectify sentences that, in hindsight, appear disproportionately severe.

Conclusion

Accordingly, the Court affirmed the District Court’s order reducing Johnson’s sentence to 35 years in prison. No remand or further instructions were issued because the reduction was within the District Court’s authority under § 3582(c)(1)(A). See: United States v. Johnson, 2025 U.S. App. LEXIS 16661 (4th Cir. 2025).  

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