The U.S. Court of Appeals for the Eleventh Circuit affirmed the denial of compassionate release for Karamchand Doobay, also known as Raj Doobay, who is serving a 151-month federal prison sentence for conspiracy to commit wire fraud. The three-judge panel, comprising Circuit Judges Jill Pryor, Branch, and Grant, issued a per curiam opinion rejecting Doobay's appeal in case No. 25-10057.
Doobay, a naturalized Canadian citizen, has been incarcerated since 2016 after running a Ponzi scheme from Florida that defrauded at least 84 investors out of more than $8 million. Following his arrest, his wife relocated to Canada with their four children, who are currently aged 29, 22, 19, and 17.
The case represents Doobay's third attempt at securing compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i), which allows for sentence reductions in cases involving extraordinary and compelling circumstances. The defendant filed his most recent motion for compassionate release in July 2024, arguing that his family's situation warranted early release from his federal sentence.
The Eleventh Circuit panel found that Doobay failed to demonstrate that his family's circumstances meet the stringent legal standard required for compassionate release. Under federal law, compassionate release requires a showing of extraordinary and compelling reasons that could not have been reasonably foreseen by the sentencing court at the time of sentencing.
The court's opinion, marked as "NOT FOR PUBLICATION," indicates this case was decided on the non-argument calendar, meaning the panel reviewed the matter based on written submissions without oral arguments. This procedural designation suggests the court viewed the legal issues as straightforward and not requiring extensive oral advocacy.
Doobay's criminal case originated in the U.S. District Court for the Middle District of Florida under docket number 3:16-cr-00122-TJC-MCR-1. His conviction on two counts of conspiracy to commit wire fraud resulted from his operation of a fraudulent investment scheme that targeted dozens of victims across multiple states.
The Ponzi scheme operated while Doobay was living in Florida, where he solicited investments from individuals by making false representations about the nature and safety of their investments. The scheme collapsed when Doobay could no longer pay earlier investors with funds from new investors, a hallmark characteristic of Ponzi fraud operations.
Compassionate release motions have become increasingly common in federal courts, particularly following legislative changes that expanded defendants' ability to petition courts directly for sentence reductions. The First Step Act of 2018 modified federal compassionate release provisions to allow defendants to petition courts directly after exhausting administrative remedies with the Bureau of Prisons.
However, federal courts maintain strict standards for granting such motions. The extraordinary and compelling circumstances standard requires more than ordinary family hardship or the typical challenges faced by incarcerated individuals and their families. Courts typically require evidence of terminal illness, debilitating medical conditions, or other circumstances that were unforeseeable at sentencing.
The Eleventh Circuit's decision reflects the federal judiciary's cautious approach to compassionate release requests, particularly in cases involving significant financial crimes. White-collar offenses like Ponzi schemes often result in substantial victim losses and lengthy sentences designed to provide both punishment and deterrence.
Doobay's case highlights the challenges defendants face when seeking early release based on family circumstances. While separation from family members during incarceration creates genuine hardship, courts generally view such consequences as foreseeable results of criminal sentencing rather than extraordinary circumstances warranting sentence modification.
The appellate court's affirmance means Doobay will continue serving his original 151-month sentence unless he can successfully petition for relief through other legal mechanisms. The Bureau of Prisons calculates federal sentences with credit for good behavior, which can reduce actual time served below the imposed sentence length.
This decision joins a growing body of federal appellate precedent addressing compassionate release standards in the post-First Step Act era. As more defendants seek early release through these provisions, courts continue refining the boundaries of what constitutes extraordinary and compelling circumstances sufficient to justify sentence reductions.
The case serves as a reminder that federal sentencing reflects not only punishment for individual defendants but also broader considerations of deterrence and justice for crime victims. In financial fraud cases involving multiple victims and substantial losses, courts typically impose sentences designed to address the serious nature of the offenses and their impact on victims and communities.