Sixth Circuit Denies COVID-19 Compassionate Release to Inmate With Hydrocephalus

Above: Defendant Caleb Lambert — Image Source: Mansfield News Journal

On appeal on November 13, 2020, the United States Court of Appeals for the Sixth Circuit affirmed the District Court’s decision to deny Caleb Lambert’s motion for compassionate release, finding that his brain condition of hydrocephalus was not sufficient to “demonstrate extraordinary and compelling reasons to justify release.”

In 2015, Caleb Lambert was sentenced to 121 months’ imprisonment after pleading guilty to two counts of armed bank robbery and one count of possessing and brandishing a firearm during the robberies. Lambert was 21 years old at the time of his offenses. On July 6, 2020, Lambert filed a motion to the District Court for the Northern District of Ohio seeking compassionate release under the First Step Act. He asserted that his condition of hydrocephalus made him more vulnerable to contracting COVID-19 in prison. The First Step Act, signed into law by President Trump in 2018, is a bipartisan criminal justice bill intended to reform federal prisons and sentencing laws. The bill in part requires that the criminogenic needs of all federal prisoners are addressed. The First Step Act has been frequently cited in prisoners’ appeals since the start of the COVID-19 pandemic, as the Bureau of Protections has been directed to review the sentences of all prisoners with COVID-19 risk factors.

In response to Lambert’s request for compassionate release, the District Court found that the “Defendant has failed to demonstrate extraordinary and compelling reasons to justify release.” On November 13, 2020, Lambert filed an appeal to the United States Court of Appeals claiming that the District Court abused their discretion. Lambert argued that the District Court relied on the government’s misstatement related to lack of evidence of hydrocephalus to come to their decision. However, on November 13, 2020, the United States Court of Appeals affirmed the District Court’s decision and denied Lambert’s compassionate release petition. The court stated in its opinion that “[they] see no reason to think that the district court relied on the government’s misstatement,” arguing that the defendant was able to correct the government’s inaccurate statement in a reply brief, which was presumably read and confirmed before their final determination was made.

Key Words: Compassionate release, hydrocephalus, COVID-19, First Step Act, Ohio

Citation: United States v. Lambert, 829 Fed.Appx. 117 (C.A.6 (Ohio), 2020)

This post is the 25th post as part of an ongoing Center for Law, Brain & Behavior (CLBB) series tracking the latest developments in law and neuroscience cases. To see previous posts about recent cases, see the full case archive on the CLBB website. To see updates on legal scholarship, see the Neurolaw News, hosted by the MacArthur Foundation Research Network on Law and Neuroscience. This project is made possible through support of the Dana Foundation.




at Mass General Hospital, Harvard Medical School

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Center for Law, Brain & Behavior

Center for Law, Brain & Behavior

at Mass General Hospital, Harvard Medical School

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