United States v. Worrell — Fourth Circuit upheld denial of sentence reduction

Case
United States of America v. Steve Michael Worrell
Court
U.S. Court of Appeals for the Fourth Circuit
Judge
King; Heytens; Benjamin
Date Decided
September 1, 2026
Docket No.
26-6615
Topics
Compassionate Release; Sentence Reduction; First Step Act
Source
Read the full opinion

Background

Steve Michael Worrell, proceeding pro se, sought a sentence reduction under 18 U.S.C. § 3582(c)(1)(A), as amended by the First Step Act of 2018. The U.S. District Court for the District of South Carolina denied his motion.

The district court also struck part of an attachment to Worrell’s motion. Worrell appealed both orders to the Fourth Circuit.

The Court’s Holding

The Fourth Circuit affirmed both district court orders. After reviewing the record under the standard applicable to denials of § 3582(c)(1)(A) motions, the panel found no reversible error.

The unpublished per curiam opinion did not provide further analysis of Worrell’s grounds for relief or the district court’s reasons. The court resolved the appeal without oral argument because the written materials adequately presented the facts and legal issues and argument would not aid the decisional process.

Key Takeaways

  • The denial of Worrell’s motion for a sentence reduction under § 3582(c)(1)(A) was affirmed.
  • The Fourth Circuit also upheld the order striking part of an attachment to the motion.
  • The unpublished opinion is not binding precedent in the Fourth Circuit.

Why It Matters

The decision leaves Worrell’s sentence and the district court’s challenged filing ruling intact. Because the Fourth Circuit offered only a record-based finding of no reversible error, the opinion supplies little additional guidance for future compassionate-release cases.

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