A federal appeals court on Tuesday rejected a bid for compassionate release from a man serving a life sentence for a pair of 1993 South Florida storefront firebombings that left one person dead and others injured.
The U.S. Court of Appeals for the Eleventh Circuit affirmed a lower court’s decision to deny a sentence reduction for Terrence Smith, also known as “Terry.” Smith, who was 19 years old at the time of the crimes, had argued that his youth, his rehabilitation behind bars, and the length of his sentence constituted extraordinary and compelling reasons to warrant his release.
According to court records, Smith and a co-conspirator threw a firebomb into Lucille’s Market in Miami on March 23, 1993, destroying the building. Four months later, on July 23, 1993, Smith and two other individuals targeted the B&B Fish Market in Pompano Beach with another firebomb. The second attack resulted in the death of one occupant and caused non-fatal injuries to several others.
A federal jury later convicted Smith of arson and damaging and destroying buildings used in interstate commerce by means of fire and explosives, specifically finding that personal injury and death resulted from the offenses. On July 30, 2001, a federal district court sentenced Smith to a 60-month term concurrent with life in prison.
Smith filed his motion for a sentence reduction in June 2025, pointing to his upbringing, his moral development while incarcerated, and sentencing disparities compared to other defendants. The district court denied the motion, ruling that the legal factors weighed heavily against his release.
In its per curiam opinion, the three-judge appellate panel—consisting of Circuit Judges Abudu, Tjoflat, and Anderson—agreed with the lower court, noting that federal law severely limits when a sentence can be modified.
The court ruled that Smith’s youth at the time of the incident did not meet the legal criteria for compassionate release. The judges also addressed his arguments regarding a past amendment to the federal sentencing guidelines regarding youthfulness, noting it was never made retroactive.
“Rehabilitation of the defendant is not, by itself, an extraordinary and compelling reason for purposes of this policy statement,” the court noted, citing sentencing guidelines.
Because the panel determined that no extraordinary and compelling circumstances existed to legally justify a reduction, it affirmed the district court’s original order keeping Smith’s life sentence intact.
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