Escapee from Federal Prison Camp is not a “Non-Secure” Facility for Purposes of Sentence Reduction
Escapee from Federal Prison Camp is not a “Non-Secure” Facility for Purposes of Sentence Reduction
On July 10, 2014, the U.S. Court of Appeals for the Eighth Circuit held that a prisoner who escaped from a federal prison camp was not entitled to a sentence reduction under the federal sentencing guidelines.
Adrian Batts walked away from a federal prison camp in Forrest City, Arkansas. He was apprehended one month later and pled guilty to one count of escape of a prisoner in custody, in violation of 18 U.S.C. § 751(a), and sentenced to 24 months in prison.
The sentencing court rejected Batts' argument that he was entitled to a four-level reduction to his base offense because, argued Batts, he escaped from a "non-secure" facility. Under the federal sentencing guidelines (USSG), such a reduction is called for when the prisoner escapes from a community corrections center, halfway house, or "similar facility." Batts argued that a prison camp was a facility similar to a halfway house because it did not have a perimeter fence.
The Eighth Circuit denied Batts' appeal, relying on decisions of its sister circuits which distinguished prison camps from the "non-secure institutions listed in USSG § 2P.1(b)(3).
See: United States v. Batts, 758 F.3d 915 (8th Cir., 2014).
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Related legal case
United States v. Batts
| Year | 2014 |
|---|---|
| Cite | 758 F.3d 915 (8th Cir., 2014) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
| Appeals Court Edition | F.3d |