District of Columbia Court of Appeals

Allen v. United States

July 30, 2026

Summary

The District of Columbia Court of Appeals vacated the trial court's denial of Henry Allen's motion for compassionate release under D.C. Code § 24-403.04(a)(3). The court held that trial courts may consider a movant's rehabilitation when assessing eligibility under the catch-all provision, and that trial courts must weigh all relevant factors collectively in their totality rather than piecemeal. Associate Judge Shanker concurred in the totality holding but dissented from the rehabilitation holding, arguing that the statute's text, structure, and legislative history limit eligibility to compassion-based factors relating to age, infirmity, and family welfare.