govinfo:USCOURTS-ilsd-3_20-cr-30158-0

IN THE UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF ILLINOIS 
 
UNITED STATES OF AMERICA, 
 
Plaintiff, 
 
vs. 
 
MEREDITH FORSON, 
 
Defendant. 
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MEMORANDUM & ORDER 
 
DUGAN, District Judge: 
 Defendant Meredith Forson has filed a pro se Motion for Compassionate Release 
Pursuant to 18 U.S.C. § 3582(c)(1)(A) and First Step Act of 2018. (Doc. 211). The 
Government has responded (Doc. 213), and Forson has replied (Doc. 214). For the reasons 
set forth below, the motion is DENIED. 
I. BACKGROUND 
Defendant was convicted for her leadership role in a conspiracy to distribute 
methamphetamine in Illinois from approximately December 2018 through July 2020. The 
Defendant’s drug trafficking organization distributed fifty pounds (22.74 kilograms) of 
methamphetamine during the conspiracy period. (Doc. 1; Doc. 45 at 9, ¶¶ 38, 43; Doc. 59). 
The charges arising from this conduct carried statutory mandatory minimum sentences. 
Specifically, three counts of conviction expo sed the Defendant to a statutory penalty 
range of ten years to life imprisonment under 21 U.S.C. § 846 and 21 U.S.C. § 841(b)(1)(A). 
The advisory sentencing guidelines produced a substantial range. The total offense 
level was calculated at 37 based on the drug quantity of 22.74 kilograms of ice Page ID
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methamphetamine, enhanced by two levels for the Defendant’s role as an organizer or 
leader, and reduced by three levels for acceptance of responsibility following her timely 
guilty plea. (Doc. 45 at 9-10). The Defendant’s criminal history score of five points placed 
her in criminal history category III. (Doc. 45 at 12). These calculations yielded an advisory 
guideline range of 262 to 327 months’ imprisonment for Counts 1, 2, and 4, while the 
sentence on Count 3 was subject to the statutory maximum of 240 months. 
On September 8, 2021, the Court sentenced the Defendant to 176 months’ imprisonment. 
(Doc. 59 at 2). 
II. STATED GROUNDS FOR RELIEF 
Defendant moves for compassionate release under 18 U.S.C. § 3582(c)(1)(A) , as 
amended by the First Step Act of 2018. (Doc. 211). She asserts that she exhausted her 
administrative remedies by submitting a request for sentence reduction to the warden on 
May 23, 2025, citing “USSG Amendment 814” 1 and § 3582(c)(1)(A). The warden denied 
the request. 
Defendant advances several grounds for relief. She contends that she suffers from 
coronary artery calcification and hyperlipid emia, conditions that cannot be adequately 
managed in prison because it is impossible to maintain a heart-healthy diet or exercise 
regimen while incarcerated. She further claims “remarkable” rehabilitation, evidenced 
 
1 Defendant’s May 23, 2025, request to the warden cited “USSG Amendment 814.” The Court presumes 
Defendant is referencing the United States Sentencing Commission’s November 2023 amendment adding 
the “Unusually Long Sentence” category to U.S.S.G. § 1B1.13(b)(6) as an extraordinary and compelling 
reason for compassionate release under 18 U.S.C. § 3582(c)(1)(A). See USSG App. C, Amdt. 814 (Nov. 2023). 
The Supreme Court has since held that this amendment exceeds the Commission’s statutory authority. See 
Rutherford v. United States, 146 S. Ct. 1320 (2026); Fernandez v. United States, 146 S. Ct. 1292, 1304 (2026) (“That 
amendment, while not relevant here, exceeds the Commission’s authority.” (citing Rutherford)). Page ID
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by consistent participation in BOP programming, a low recidivism risk assessment, a 
disciplinary-free record, and contributions to the inmate community through crocheting 
and knitting items for donation as well as providing emotional support to fellow inmates. 
Defendant also argues that the purity of the methamphetamine attributed to her 
at sentencing substantially increased her sentence and that a proposed amendment to the 
Sentencing Guidelines addressing the distinction between methamphetamine mixtures 
and actual methamphetamine would have significantly reduced her base offense level 
and overall sentence. Although she acknowledges that the proposed amendment has not 
been enacted or made retroactive under U.S.S.G. § 1B1.10 , she maintains that it “may 
form part” of the Court’s analysis because her original sentence is now unduly harsh and 
inconsistent with current sentencing practices. (Doc. 211, pg. 17); ( see also Id . at pg. 18) 
(“In light of the upcoming amendment and the legal recogn ition that non-retroactive 
sentencing reforms can support compassionate release, [Defendant’s] continued 
incarceration is no longer consistent with the principles of fairness, proportionality, or 
justice.”). Finally, Defendant contends that her 2021 sentence is disproportionate when 
compared to sentences imposed on similarly situated defendants after the First Step Act 
and that this disparity, combined with her age and medical conditions, supports release. 
The Government opposes the motion on multiple grounds. It first argues that 
Defendant failed to exhaust administrative remedies with respect to her medical claims. 
Her May 2025 request to the warden sought relief solely under U.S.S.G. § 1B1.13(b)(6) on 
the basis of an unusually long sentence and did not raise medical grounds. Even 
assuming exhaustion, the Government contends that Defendant’s health claims fail for Page ID
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lack of supporting medical documentation. 
On the merits, the Government argues th at Defendant does not qualify for relief. 
She cannot proceed under § 1B1.13(b)(6) because she has not served at least ten years of 
her sentence and because the proposed methamphetamine-purity amendment has 
neither been enacted nor made retroactive, either of which, standing alone, precludes 
relief under Seventh Circuit authority. The Government further notes that, under the 
current Guidelines, Defendant’s advisory range would be 210–262 months, compared 
with her original range of 262–327 months which does show a gross disparity. In addition, 
the Government argues, pursuant to United States v. Thacker , 4 F.4th 569 (7th Cir. 2021) , 
courts lack authority to use § 3582(c)(1)(A) to circumvent statutory mandatory minimum 
sentences, and Defendant is serving three ten-year mandatory minimum terms. Finally, 
allegations of rehabilitation alone are statutorily insufficient to establish an extraordinary 
and compelling reason. 
In reply, Defendant argues that exhaustion does not require strict “issue-
matching” or previewing every argument ultimately raised in court. She maintains that 
her motion rests on traditional extraordinary and compelling reasons (medical 
circumstances and rehabilitation) already recognized in the Seventh Circuit, together 
with the § 3553(a) factors, and that she is not invoking § 1B1.13(b)(6) at all. Because she is 
not proceeding under subsection (b)(6), De fendant contends that the Government’s 
arguments concerning that provision are irrelevant. Instead, Defendant urges the Court 
to focus on unwarranted national disparities and to conduct a holistic assessment of the 
totality of the circumstances. While acknowledging that rehabilitation alone is statutorily Page ID
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insufficient, she emphasizes that the Supreme Court has described it as “highly relevant.” 
See Pepper v. United States , 562 U.S. 476 (2011) . She further argues that Thacker does not 
bar relief where, as here, independent extraordinary and compelling reasons exist 
alongside considerations of current sentencing practices and national disparities. 
III. A PPLICABLE LAW
Generally, a court is statutorily prohibited from modifying a term of 
imprisonment once imposed. See 18 U.S.C. § 3582(c) . Section 3582(c)(1)(A) however 
authorizes a district court to reduce a defendant's sentence, after considering the 
sentencing factors described in 18 U.S.C. § 3553(a) , if the court finds that (1) 
extraordinary and compelling reasons warrant a sentence reduction and (2) a sentence 
reduction is consistent with “applicable policy statements issued by the Sentencing 
Commission.” The Sentencing Commission's policy statement applicable 
to compassionate release requests was recently amended. See Sentencing Guidelines 
§ 1B1.13. 
Section 1B1.13(b) describes six categories of extraordinary and compelling reasons 
that individually, or in combination, may support a defendant's request 
for compassionate release: (1) medical circumstances of the defendant; (2) advanced age; 
(3) family circumstances; (4) sexual or physical abuse suffered by the defendant while in 
custody involving a “sexual act” or “serious bodily injury”; (5) “other reasons” similar in 
gravity as those articulated in (1)-(4); and (6) an unusually long sentence. 
When evaluating whether compelling and extraordinary circumstances exist, a 
court must “consider[ ] the applicant's individualized arguments and evidence.” United Page ID
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States v. Rucker , 27 F.4th 560, 563 (7th Cir. 2022) . Ultimately, the defendant bears 
the burden of demonstrating “extraordinary and compelling reasons” warranting a 
sentence reduction. United States v. Newton, 996 F.3d 485, 488 (7th Cir. 2021). 
IV. Discussion 
A. Exhaustion 
The Government has raised the affi rmative defense that Defendant failed to 
exhaust her administrative remedies under 18 U.S.C. § 3582(c)(1)(A) . Because the 
Government has properly invoked this mandatory claim-processing rule, Defendant 
must demonstrate that she has satisfied the exhaustion requirement as to the grounds she 
now advances in her motion. See United States v. Sanford, 986 F.3d 779, 782 (7th Cir. 2021). 
Prisoners have two routes to directly petition courts for compassionate release: (1) 
file a motion after fully exhausting administrative appeals of the BOP's decision not to 
file a motion for compassionate release, or (2) file a motion after “the lapse of 30 days 
from the receipt...of such a request” by the warden of the prisoner's facility, whichever is 
earlier. 18 U.S.C. § 3582(c)(1)(A). 
To properly exhaust, the defendant must have “present[ed] the same or similar 
ground for compassionate release in a request to the Bureau as in [the] motion to the 
court.” United States v. Williams, 987 F.3d 700, 703 (7th Cir. 2021). 2 This issue-exhaustion 
rule affords the Bureau an opportunity to evaluate the defendant’s specific claims before 
they are brought to federal court. Id. 
 
2 Defendant misreads United States v. Williams , 987 F.3d 700 (7 th Cir. 2021) . Far from holding that issue 
exhaustion is unnecessary, the Seventh Circuit exp ressly required that a defendant present the same or 
similar grounds to the Bureau of Prisons in the administrative request. Page ID
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Defendant submitted her request for compassionate release to the Warden on May 
25, 2025. (Doc. 211-1, pg. 2). The request was captioned as a “Request for Sentence 
Reduction Consideration Pursuant to USSG Amendment 814 & U.S.C. 3582(c)(1)(A).” In 
the request, Defendant contended that if sentenced today she would not have received 
the “pure meth” enhancement, due to categorical changes in applicable offenses and 
intervening legal decisions, and that this change constitutes an “extraordinary and 
compelling reason” under the amended guidelines. (Id.). Defendant made no mention of 
any medical conditions, rehabilitation efforts, or other potential extraordinary and 
compelling circumstances. 
On June 17, 2025, the Warden responded, denying Defendant’s request stating in 
relevant part: 
Per Program Statement 5050.50 Compassionate Release/Reduction in 
Sentence: Procedures for Implementation of 18 U.S.C. §§ 3582(c)(1)(A) and 
4205(g), there are certain criteria which you must meet in order to be 
considered for [a Reduction in Sentence based on non-medical 
circumstances/extraordinary and compelling reason]. The request was 
received and reviewed. At this time, it appears you do not meet criteria. 
Although, the Federal Courts have recently amended Request for Sentence 
Reduction Consideration Pursuant to USSG Amendment 814 & 18 U.S.C. 
3582(c)(1)(A), this change has yet to be acknowledged in the Bureau of 
Prison’s current Policy. 
 
(Doc. 211-1, pg. 3). 
Defendant filed the present motion on September 16, 2025, more than thirty days 
after the warden received her request. Becaus e Defendant’s administrative request did 
not raise medical conditions or rehabilitation as grounds for relief, those claims are 
unexhausted. They must therefore be dismissed for failure to exhaust administrative Page ID
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remedies. However, even assuming arguendo that the medical and rehabilitation claims 
were properly exhausted, they would fail on the merits for the reasons set forth below. 
By contrast, Defendant’s May 23, 2025 request to the warden specifically raised the 
claim that the Sentencing Commission’s November 2023 amendment adding the 
“Unusually Long Sentence” category to U.S.S.G. § 1B1.13(b)(6), together with intervening 
changes in the law regarding the methamphetamine purity enhancement, constitutes an 
extraordinary and compelling reason for a sentence reduction. The Court finds that the 
claims in the instant motion pertaining to alleged sentencing disparities and an unusually 
long sentence are sufficiently similar to those raised in her administrative request and are 
therefore properly exhausted. Nonetheless, as discussed below, these claims also fail on 
the merits. 
B. Merits Analysis 
1. Medical Conditions 
Defendant claims she suffers from coronary artery calcification and 
hyperlipidemia and that, despite medication, these conditions cannot be properly 
managed because she cannot maintain an exercise regimen or a heart-healthy diet while 
incarcerated. These allegations do not satisfy any of the criteria in U.S.S.G. § 1B1.13(b)(1). 
There is no evidence that the conditions are terminal, substantially diminish her ability 
to provide self-care in the correctional setting, require long-term or specialized care that 
the BOP is not providing, or place her at serious risk from an infectious disease outbreak. 
Critically, Defendant has provided no evidentiary support whatsoever for these medical 
claims. She has submitted no medical records, no BOP treatment documentation, no Page ID
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physician statements, and no other materials demonstrating the severity or impact of 
these conditions. The movant bears the burden of proving extraordinary and compelling 
reasons. Newton, 996 F.3d at 488. Where a defendant fails to furnish any medical evidence 
regarding the severity of claimed conditions, the claim necessarily fails. See United States 
v. Scott, 850 F. App’x 449, 451 (7th Cir. 2021). Accordingly, even if exhausted, this ground 
would fail on the merits. 
2. Remaining Claims 
To the extent Defendant relies on U.S.S.G. § 1B1.13(b)(6), she is ineligible. She has 
not served at least ten years of her sentence. More fundamentally, the Supreme Court has 
held that this provision exceeds the Sent encing Commission’s st atutory authority. See 
Fernandez v. United States , 146 S. Ct. 1292, 1304 (2026) (citing Rutherford v. United States , 
146 S. Ct. 1320 (2026)). 
Although Defendant disclaims reliance on § 1B1.13(b)(6), she maintains that her 
sentence is unusually long or disparate under the current Gu idelines and/or would be 
under a proposed (but unenacted) amendment addressing the methamphetamine purity 
distinction between actual methamphetamine and mixtures.3 She contends this argument 
remains viable independently of subsection (b)(6). The contention is unavailing. 
 
3 The Sentencing Commission published proposed amendments addressing offenses involving “Ice” and 
the purity distinction between metham phetamine in “actual” form and meth amphetamine as part of a 
mixture in December 2025. See Proposed 2026 Amendments to the Federal Sentencing Guidelines (U.S. 
Sent’g Comm’n Dec. 2025), at 2–5, https://www.ussc.gov/sites/default/files/pdf/amendment-
process/reader-friendly-amendments/202512_rf-proposed.pdf; 90 Fed. Reg. 59662 (Dec. 29, 2025) . The 
public comment period closed on February 10, 2026. The Commission has not yet adopted any final version 
of the amendments or determined whether they (or any portion) would be made retroactively applicable 
under U.S.S.G. § 1B1.10. Page ID
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Whether framed under subsection (b)(6) or advanced independently, these claims 
fail. Defendant cannot obtain indirectly what the statute and controlling precedent forbid 
directly. In Rutherford v. United States , 608 U.S. ___, 146 S. Ct. 1320 (2026) , the Supreme 
Court held that when Congress declines to make a sentencing amendment retroactive, 
any resulting disparity between a pre-amendment sentence and the sentence that would 
be imposed today does not constitute an “extraordinary and compelling reason” 
warranting reduction under 18 U.S.C. § 3582(c)(1)(A). Such disparities are ordinary, not 
extraordinary. Treating them as compelling would undermine Congress’s deliberate 
choice to limit new penalties to future offenders. Compassionate release addresses 
prisoners’ personal circumstances that warrant mercy, not generalized disagreements 
with sentencing policy or disparities created by non-retroactive changes. Id. at 1330-35.4 
In the instant case, no change in the law, retroactive or otherwise, has produced a 
gross disparity. As noted by the Government, Defendant’s recalculated Guidelines range 
under current law is 210–262 months. While lower than her original calculated range, this 
does not constitute a “gross disparity” when measured against the 176-month sentence 
actually imposed, which already reflected a substantial downward variance and was 
anchored by three ten-year mandatory minimum terms. Furthermore, arguments raising 
policy disagreements, including those with the methamphetamine Guidelines or purity-
based disparity arguments, have been rejected as grounds for compassionate release. See, 
 
4 The Seventh Circuit reached the same conclusion in United States v. Thacker , 4 F.4th 569 (7th Cir. 2021) , 
holding that a non-retroactive change in law cannot constitute an extraordinary and compelling reason, 
alone or in combination with other factors. Id. at 571 , 573–74. See also United States v. Black , 131 F.4th 542 
(7th Cir. 2025). Page ID
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e.g., United States v. Alldredge, 2025 WL 1875100, at *2–3 (N.D. Ind. July 7, 2025) (denying 
similar claim).5 
The Defendant’s alleged rehabilitation is commendable. Under 28 U.S.C. § 994(t) 
and U.S.S.G. § 1B1.13(d) , however, rehabilitation alone is not an extraordinary and 
compelling reason. It may be considered in combination with other factors, but it cannot 
transform insufficient grounds into extraordinary and compelling circumstances. See 
Rutherford, 146 S. Ct. at 1334 -35; Thacker, 4 F.4th at 576. See also United States v. Jarvis, 999 
F.3d 442, 444 (2021) (“[A]dding a legally impermissible ground to three insufficient 
factual considerations does not entitle a defendant to a sentence reduction.”). 
To the extent the Defendant invokes the catch-all in U.S.S.G. § 1B1.13(b)(5) , it 
requires circumstances “similar in gravity” to the enumerated categories (serious medical 
conditions, advanced age with deterioration, family caregiver needs, or victimization by 
sexual or physical abuse in custody). Defendant’s claims do not meet this threshold. Even 
when considered cumulatively with the Defendant’s other arguments, these grounds fall 
short. 
Despite her arguments to the contrary, Defendant is effectively seeking to 
circumvent three concurrent ten-year statutory mandatory minimum sentences. In 
Thacker, the Seventh Circuit held that § 3582(c)(1)(A) does not authorize a district court to 
 
5 Additionally, arguments for comp assionate release or sentence reduc tion based on proposed but 
unenacted guideline amendments are premature and do not constitute extraordinary and compelling 
reasons. See, e.g., United States v. Turner , No. CR 24-89, 2026 WL 472721, at *1–2 (E.D. La. Feb. 19, 2026) ; 
United States v. Watford, No. 3:97-CR-26-RLM, 2023 WL 4862905, at *2 (N.D. Ind. July 31, 2023); United States 
v. Johnson, No. 17-1569, 2023 WL 3991049, at *2 (W.D. Tex. June 13, 2023). Page ID
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reduce a sentence below a congressionally mandated minimum on the ground that a non-
retroactive change in law or policy disagreem ent with the length of a lawful mandatory 
minimum constitutes an extraordinary and compelling reason. 4 F.4th at 573 –74. 
Congress, not the judiciary, sets mandat ory minimum penalties; compassionate release 
is not a vehicle to declare a lawful mandatory minimum “too long.” Id. at 574; see also 
Rutherford, 146 S. Ct. at 1330 -35. The Defendant’s attempts to distinguish Thacker by 
asserting “independent” extraordinary and compelling reasons are unavailing. Her 
motion rests heavily on non-retroactive changes in law and/or unenacted legislation and 
resulting disparities. For the reasons discussed herein, such arguments do not provide an 
extraordinary or compelling reason for compassionate release. 
Finally, even if extraordinary and compelling reasons existed, the factors under 18 
U.S.C. § 3553(a) weigh strongly against any reduction. The Defendant was the leader and 
organizer of a significant methamphetamine trafficking organization. She is serving three 
concurrent ten-year mandatory minimum terms. Her criminal history category was III. 
The original 176-month sentence already incorporated a substantial downward variance. 
Releasing her after serving only approximately five years would fail to reflect the 
seriousness of the offense, promote respect for the law, provide just punishment, afford 
adequate deterrence, or protect the public. See 18 U.S.C. § 3553(a)(1)–(3), (6). Page ID
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V. C ONCLUSION 
 For these reasons, Defendant Meredith Forson’s Motion for Compassionate 
Release (Doc. 211) is DENIED. 
IT IS SO ORDERED. 
DATED: June 12, 2026 
 
 
 DAVID W. DUGAN 
 U. S. District Judge 
 
 
Judge 
Dugan
Digitally signed 
by Judge 
Dugan 
Date: 
2026.06.12 
11:54:08 -05'00' Page ID
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