Case Explained: UNITED STATES OF AMERICA Plaintiff – v. BRAD ACY HOLLEY Defendant –

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-07-01 The Fourth Circuit affirmed the district court’s denial of Brad Acy Holley’s motion for compassionate release based on his end-stage renal disease. The court applied the abuse of discretion standard of review to the district court’s determination that Holley’s medical condition did not constitute an “extraordinary and compelling reason” for sentence reduction under 18 U.S.C. § 3582(c)(1)(A) and U.S. Sentencing Commission Policy Statement § 1B1.13. The court held that the district court did not abuse its discretion in rejecting Holley’s arguments on two grounds. First, regarding the claim of terminal illness, the court affirmed that end-stage organ disease is not categorically a terminal illness; rather, the district court correctly found that Holley’s specific medical records showed his condition was responding well to treatment and lacked an “end-of-life trajectory,” distinguishing his case from generalized statistical life expectancies. Second, regarding the claim of inadequate medical care, the court affirmed that the Bureau of Prisons was providing Holley with regular, thorough care including dialysis and specialist consultations, and that there was no record evidence proving he could not receive a kidney transplant in prison or that he would be more likely to receive one upon release. Additionally, the court rejected Holley’s procedural arguments regarding the denial of appointed counsel and an expert witness. Citing *United States v. Legree*, the court confirmed there is no constitutional or statutory right to appointed counsel in § 3582(c) proceedings, and found no exceptional circumstances required to exercise the district court’s discretionary authority under 28 U.S.C. § 1915(e)(1). Similarly, the appointment of a court-appointed expert witness was deemed unnecessary as the district judge could understand the medical issues without such assistance. As a result of this decision, Holley’s sentence remains unchanged, and he must continue serving his 127-month term in federal custody. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.