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Judge Orders Federal Prisoner with Cancer Released Due to Poor Medical Care

by Matt Clarke

In June 2019, a U.S. District Court ordered that a prisoner held at the Federal Correctional Institution in Aliceville, Alabama be released due to the poor medical care she received from the Bureau of Prisons (BOP) for invasive breast cancer.

In 2013, Angela Michelle Beck, 47, pleaded guilty to conspiracy to distribute methamphetamine and possession of a firearm in connection with a drug trafficking offense. She was one of 21 people indicted on charges of being part of a large-scale methamphetamine ring, and received a 166-month sentence. She had served over six years.

According to court documents, Beck found a lump in her left breast while taking a shower in September 2017. She reported the lump to prison officials and was seen by a doctor on October 16, 2017, then by a surgeon two months later. She had a mammogram on December 21, 2017 that showed multiple breast masses and cysts. A prison doctor ordered a biopsy.

Eight months later, the biopsy confirmed Stage II cancer and Beck was told she would need to have the breast removed. That didn’t happen for another three months. It took five more months before she received a follow-up appointment with an oncologist for further treatment. By then it was too late for chemotherapy, and she had found two lumps in her right breast.

Attorneys Robert Elliot of Winston-Salem and James B. Craven III of Durham helped Beck apply for compassionate release under the provisions of the First Step Act. On June 28, 2019, U.S. District Court Judge Catherine Eagles issued a 29-page order reducing Beck’s sentence to time served and granting compassionate release.

Judge Eagles gave BOP officials 21 days to evaluate Beck’s residence and implement a five-year period of supervised probation. In her order, Eagles said she had granted compassionate release due to Beck’s “invasive cancer and the abysmal health care [that the] Bureau of Prisons has provided,” which qualified “as ‘extraordinary and compelling reasons’ warranting a reduction in her sentence to time served.”

“With appropriate supervision, the court concludes that Ms. Beck ‘is not a danger to the safety of any other person or to the community,’” Judge Eagles wrote. “Ms. Beck poses little risk of recidivism or danger to the community.... As such, Ms. Beck is entitled to compassionate release.”

BOP officials did not deny any of the allegations in Beck’s request for compassionate release or provide an explanation for the delay in her medical care. However, they did argue, unsuccessfully, that she did not qualify for compassionate release because she didn’t have a terminal disease or a debilitating medical condition that prevented her from taking care of herself, and that she may still “present a danger to the community given the seriousness of her offenses.”

Beck had previously filed a lawsuit seeking an order requiring the BOP to provide treatment for her cancer. In that case, which was also heard by Judge Eagles, prison officials were ordered to ensure that Beck received immediate medical care. In granting compassionate release, Eagles noted that the BOP “continues to justify delays by blaming non-BOP officials, such as her oncologist, and logistical issues, and it has provided erroneous information about her recent appointments to the Court. The quality of Ms. Beck’s cancer treatment at [the BOP] in the past remains the best predictor of what it will be in the future.” See: United States v. Beck, U.S.D.C. (M.D. NC), Case No. 1:13-cr-00186-6-CCE; 2019 U.S. Dist. LEXIS 108542. 


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Related legal case

United States v. Beck