Case Explained: UNITED STATES OF AMERICA v. MARION QUINTON BREWSTER

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-24 The Fourth Circuit affirmed the district court’s order denying Marion Quinton Brewster’s motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A). The court reviewed the denial of the motion for abuse of discretion and the interpretation of the statute de novo, limiting its review to issues preserved in the appellant’s informal brief. The court held that while intervening case law regarding the Armed Career Criminal Act (ACCA) could theoretically constitute an “extraordinary and compelling reason” by creating a sentencing disparity, Brewster failed to meet the specific eligibility requirements set forth in the Sentencing Commission’s amended policy statement, U.S. Sentencing Guidelines Manual § 1B1.13. Under § 1B1.13(b)(6), a change in the law qualifies as an extraordinary and compelling reason only if the movant has served at least ten years of imprisonment. Because Brewster had not yet served ten years, the court found no reversible error in the district court’s refusal to consider this factor. The court noted that Brewster may file a new motion before the district court once he satisfies the ten-year requirement. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.