UNITED STATES v. OWENS (2025)

ORDER

This matter comes before the court on the Government's Motion to Stay Proceedings and Suspend Briefing (“Motion”), filed on October 6, 2025, pending the United States Supreme Court's decisions in the cases of Carter v. United States, No. 24-860, 145 S. Ct. 2775 (2025), and Rutherford v. United States, No. 24-820, 145 S. Ct. 2776 (2025). ECF No. 120. In the Motion, the Government asks the court to stay proceedings in Defendant's Motion for Reduction in Sentence Under 18 U.S.C. § 3582(c)(1)(A)(i). Id. at 1-2; see ECF No. 116 (“Motion for Reduction in Sentence”). For the reasons stated below, the court GRANTS the Government's Motion.

I.

On February 4, 1998, after a three-day trial, a jury found Defendant guilty of six (6) counts of the Indictment. ECF No. 29.¹ On May 7, 1998, the court entered Judgment against Defendant and sentenced him to a total term of life plus three hundred (300) months imprisonment. ECF No. 34.

On August 16, 2025, Defendant filed a Motion for Reduction in Sentence Under 18 U.S.C. § 3582(c)(1)(A)(i), seeking compassionate release in accordance with the United States Sentencing Guidelines (“USSG”). ECF No. 116.² Specifically, Defendant asserts he is entitled to a reduced sentence under USSG § 1B1.13(b)(6) because his sentence was “unusually long” and an “ ‘intervening change in the law’ ․ creat[es] a ‘gross disparity’ [between] the term he would face today for the same offenses.” Id. at 2-3. Defendant also contends he is entitled to a reduced sentence for “other reasons” under USSG § 1B1.13(b)(5). Id. at 3. He states that these circumstances constitute “ ‘extraordinary and compelling’ reasons” warranting relief under § 3582(c)(1)(A)(i). Id. at 1.

On August 28, 2025, the court entered an Order directing the Government to respond to Defendant's Motion for Reduction in Sentence within sixty (60) days of entry. ECF No. 117 at 3. On October 6, 2025, the Government filed the instant Motion, ECF No. 120, which comes before the filing deadline set in this court's August 28, 2025, Order, ECF No. 117.

In the Motion, the Government argues that the decisions in the cases of Carter and Rutherford, currently pending before the Supreme Court, will directly impact the instant case and warrant a stay in these proceedings. ECF No. 120 at 1. The question presented in Carter is whether “the [United States] Sentencing Commission permissibly exercised its authority when it described a ‘change in the law,’ such as the First Step Act's nonretroactive amendments, as a valid consideration in determining whether a defendant has established ‘extraordinary and compelling reasons’ for a sentence reduction under § 1B1.13(b)(6).” Id. at 2-3 (citing Carter, No. 24-860). Similarly, in Rutherford, the Court will decide whether “a district court may consider sentencing disparities created by the First Step Act's nonretroactive amendments in determining whether a defendant has established ‘extraordinary and compelling reasons’ for a sentence reduction under § 3582(c)(1)(A)(i).” Id. at 2 (citing Rutherford, No. 24-820). The Court consolidated the cases for oral argument, which is scheduled for November 12, 2025. Id. at 3.

II.

Federal courts have long recognized that a “[d]istrict [c]ourt has broad discretion to stay proceedings as an incident to its power to control its own docket,” Clinton v. Jones, 520 U.S. 681, 706 (1997), and that, in exercising its discretion, the court may consider the “economy of time and effort for itself, for counsel, and for litigants,” Maryland v. Universal Elections, Inc., 729 F.3d 370, 379 (4th Cir. 2013) (citation omitted). In particular, the court “must weigh competing interests and maintain an even balance.” Landis v. N. Am. Co., 299 U.S. 248, 254–55 (1936) (citation omitted). “The party seeking a stay must justify it by clear and convincing circumstances outweighing potential harm to the party against whom it is operative.” Williford v. Armstrong World Indus., Inc., 715 F.2d 124, 127 (4th Cir. 1983).

Upon review, the court agrees with the Government that a stay in the current proceedings is appropriate. Defendant's Motion for Reduction in Sentence is based, in large part, on the argument that a nonretroactive change in the law constitutes an extraordinary and compelling reason warranting relief under USSG § 1B1.13(b)(6). ECF No. 116 at 2-3. The questions of whether a district court may consider such changes in the law for compassionate release, and whether the United States Sentencing Commission exceeded its authority in permitting such considerations under § 1B1.13(b)(6), bear directly on Defendant's claims and will be decided in Carter and Rutherford. See ECF No. 120 at 2-3. If the court were to address Defendant's Motion for Reduction in Sentence at this juncture, any conclusions by the court could later be contradicted by that of the Supreme Court. Thus, given the basis of Defendant's Motion for Reduction in Sentence, the court believes that the Supreme Court's decisions in Carter and Rutherford “will provide substantial guidance in connection with the proper disposition of this case.” United States v. Culp, No. 92-cr-81058-10, 2025 WL 1710222 at *1 (E.D. Mich. June 18, 2025) (granting the Government's motion to stay proceedings in a defendant's compassionate release motion pending decisions in Carter and Rutherford).

Therefore, in the interest of judicial economy and avoiding potentially inconsistent results, the Government's Motion to Stay Proceedings and Suspend Briefing, ECF No. 120, in this matter is GRANTED. Accordingly, the proceedings before the court in this matter are STAYED until the Supreme Court issues its decisions in Carter v. United States, No. 24-860, and Rutherford v. United States, No. 24-820. The Government is DIRECTED to respond to Defendant's Motion for Reduction in Sentence Under 18 U.S.C. § 3582(c)(1)(A)(i), ECF No. 116, within forty-five (45) days of the date on which the Supreme Court issues decisions in these cases, and Defendant will be given an opportunity to reply.

IT IS SO ORDERED.

FOOTNOTES

1.   The jury found Defendant guilty of (1) Assault with Intent to Commit Murder, in violation of 18 U.S.C. §§ 7(3) and 113(a); (2) Robbery, in violation of 18 U.S.C. § 2111; (3) Use of a Firearm in a Crime of Violence, in violation of 18 U.S.C. § 924(c)(1) (two counts); (4) Possession of Ammunition by a Fugitive, in violation of 18 U.S.C. § 922(g)(2); and (5) Attempted Capital Murder, in violation of 18 U.S.C. §§ 7 and 13. ECF No. 29.

2.   The court accepts Defendant's Motion for Reduction in Sentence as effectively filed on the date Defendant certifies he placed it in the prison's internal mailing system, which is August 16, 2025. See Houston v. Lack, 487 U.S. 266 (1988) (articulating the “prison mailbox rule”).

REBECCA BEACH SMITH, SENIOR UNITED STATES DISTRICT JUDGE