United States v. James Hiatt

── United States v. James Hiatt ── Court: Court of Appeals for the Sixth Circuit Date: May 06, 2026 Category: General NOT RECOMMENDED FOR FULL-TEXT PUBLICATION File Name: 26a0206n.06 File Name: 26a0206n.06 No. 25-5923 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT UNITED STATES OF AMERICA, ) ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE EASTERN ) DISTRICT OF TENNESSEE JAMES EDWARD HIATT, ) Defendant-Appellant. ) OPINION ) ) Before: MOORE, WHITE, and THAPAR, Circuit Judges. KAREN NELSON MOORE, Circuit Judge. James Hiatt pleaded guilty to child- pornography offenses and was sentenced to 168 months’ imprisonment in 2018. He has since twice moved for compassionate release. Appealing the denial of his more recent motion, he argues that the district court erred in its balancing of the 18 U.S.C. § 3553(a) factors and its conclusion that they weighed against Hiatt’s release. Because we discern no abuse of discretion, we AFFIRM the decision of the district court. I. BACKGROUND In December 2015, law-enforcement officers used peer-to-peer file-sharing software to connect to James Hiatt’s computer and download a video depicting child pornography. R. 25 (Plea Agreement at 2) (Page ID #53). Officers seized Hiatt’s computer equipment pursuant to a search No. 25-5923, United States v. Hiatt warrant, and a subsequent forensic examination determined that peer-to-peer file-sharing software was installed and thousands of images and videos depicting child pornography were saved on that equipment. Id. at 3 (Page ID #54). Hiatt was indicted and pleaded guilty to two counts of distribution of child pornography in violation of 18 U.S.C. §§ 2252A(a)(2)(A) and 2252A(b)(1). R. 56 (Judgment at 1) (Page ID #1109). In March 2018, the district court sentenced Hiatt to a total term of 168 months’ imprisonment to be followed by fourteen years on supervised release. Id. at 2–3 (Page ID #1110–11). Hiatt moved pro se for compassionate release in March 2022. R. 81 (First Sent. Reduction Mot. at 1) (Page ID #1358). Hiatt represented that at that time he had served approximately six years of his sentence. Id. at 2 (Page ID #1359). He argued that his medical conditions, namely obesity and major depressive disorder, put him at increased risk of serious illness and death due to COVID-19, and that this health risk amounted to an extraordinary and compelling reason justifying compassionate release. Id. at 3–4 (Page ID #1360–61). Additionally, he argued that the 18 U.S.C. § 3553(a) factors weighed in his favor. He emphasized that the instant offense was his only criminal infraction, he had served about half of his sentence, and he had taken steps toward rehabilitation and incurred no disciplinary history while incarcerated. Id. at 4–10 (Page ID #1361– 67). The district court concluded that the § 3553(a) factors weighed against compassionate release and denied Hiatt’s motion. R. 99 (Order Denying First Sent. Reduction Mot. at 5) (Page ID #1494). The district court focused on the seriousness of Hiatt’s offenses, noting that several of the thousands of images and videos extracted from Hiatt’s computer “depicted sadism or 2 No. 25-5923, United States v. Hiatt masochi