Case Explained: UNITED STATES OF AMERICA v. CURTIS WASHINGTON

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-23 The Fourth Circuit affirmed the district court’s denial of Curtis Washington’s motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The court applied an abuse of discretion standard, reviewing whether the district court acted arbitrarily, followed statutory requirements, and conducted the necessary analysis. The appellate court held that while a change in sentencing law regarding the Armed Career Criminal Act can constitute an “extraordinary and compelling reason” for sentence reduction under U.S. Sentencing Guidelines Manual § 1B1.13, such a ground is only available to movants who have served at least ten years of imprisonment. Because Washington had not yet satisfied this ten-year service requirement, the court found no reversible error in the district court’s conclusion that he failed to demonstrate extraordinary and compelling reasons for relief. Consequently, Washington’s sentence remains unchanged, though the court noted he may file a new motion with the district court once he satisfies the ten-year imprisonment threshold. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.