On 8 April 2022, the District Court for the Southern District of New York granted in part a motion for compassionate release filed by a federal prisoner who had alleged that his medical conditions placed him "at high risk of COVID-19's worst consequences" and that, on account of the pandemic, he had suffered through truly egregious conditions of confinement that have made service of his existing sentence more onerous and more punitive than the Court originally contemplated.

After having denied the prisoner’s first argument, the Court held that pandemic-induced conditions of confinement may constitute "extraordinary and compelling" circumstances warranting compassionate release, particularly for defendants who – like the applicant in that case – have (i) served long sentences and (ii) been detained for the entirety of the pandemic. Accordingly, the Court reduced the prisoner’s sentence of ten months.

Full text of the decision available at en