In July 2021, as the COVID-19 Delta variant contributed to the\u00a0\u201crapid and alarming rise in the COVID-19 case and hospitalization rates\u00a0around the country,\u201d Wylema Wilson hand-wrote a letter to the United\u00a0States District Court for the Western District of Oklahoma, noting the\u00a0COVID-19 deaths in her prison. As a 66-year-old inmate having served\u00a0some years for drug trafficking, she \u201choped for a second chance at life, a\u00a0life the way it should be[,] clean and sober.\u201d The court denied her motion\u00a0for compassionate release, concluding that a sentence reduction \u201cwould\u00a0not reflect the seriousness of defendant’s offense.\u201d\u00a0Grim as that result might be, grimmer is the systematically lagging\u00a0trajectory of federal compassionate release reform. Until very recently,\u00a0Wylema\u2019s letter to seek early release would not even have been possible.\u00a0While the history of court-ordered compassionate release in federal law\u00a0dates back to the Sentencing Reform Act of 1984 (SRA), it was not until\u00a0the First Step Act of 2018 (FSA) that prisoners were allowed to petition\u00a0for their own compassionate release under the new phrase added to 18\u00a0U.S.C. \u00a7 3582(c) (\u201cupon motion of the defendant\u201d). Before the FSA’s\u00a0passage on December 21, 2018,7 federal courts could only reduce the term\u00a0of imprisonment \u201cupon motion of the Director of the Bureau of Prisons,\u201d\u00a0who has often been reluctant and untimely in filing the motions. It took\u00a0six bills amending 18 U.S.C. \u00a7 3582 for the federal criminal justice\u00a0system to arrive at the current Prisoner-initiated & Court-ordered (PICO)\u00a0Compassionate Release system.\u00a0But the PICO compassionate release statute\u2014which one could\u00a0argue is the bare minimum of a genuine compassionate release system,\u00a0where prisoners can have their voices heard in a public proceeding\u2014was\u00a0not first seen in the federal criminal justice system, despite strong\u00a0scholarly attention to federal compassionate release. Historical records\u00a0suggests that by 1994 at the latest, New Jersey already had a PICO\u00a0compassionate release system, first among the states. State\u00a0compassionate release practices arguably influenced federal\u00a0compassionate release reform in part through the American Law\u00a0Institute\u2019s Model Penal Code: Sentencing, the final draft of which was\u00a0approved in May 2017, a year before the introduction and passage of the\u00a0FSA.\u00a0As activists who urged its passage wrote, the FSA was a \u201cmodest\u00a0but necessary\u201d step; the pandemic and the threat it posed to the\u00a0incarcerated population ought to prompt reflections on what the next\u00a0steps should be. This Essay is intended to serve as both a brief historical\u00a0review of state influence on federal compassionate release, and as a\u00a0reflection on the unfinished compassionate release reform in terms of\u00a0DOJ\u2019s execution. Part I briefly surveys the trajectory of 18 U.S.C.\u00a0\u00a7 3582(c) from the SRA to the PICO compassionate release provision in\u00a0the FSA, and its application in the pandemic. Part II supplements the\u00a0compassionate release literature by exploring the history of PICO\u00a0compassionate release in state law as a backdrop of the long-awaited\u00a0federal reform allowing prisoners to petition for their own release, and it\u00a0proposes that state practices, especially that of New Jersey, might have\u00a0influenced the introduction and passage of FSA in part through the Model\u00a0Penal Code. Part III suggests that the arc of compassionate release reform\u00a0in federal law is nevertheless unfinished, with the Department of Justice\u2019s\u00a0(DOJ) objection practices being part of the necessary change. Using data\u00a0and cases from the District of Columbia, whose PICO compassionate\u00a0release statute is modeled after federal law and clearly intended as a\u00a0response to the pandemic, this Essay proposes that the DOJ’s perspective\u00a0and practices must change to adapt to the essential purpose of\u00a0compassionate release: addressing mass incarceration in America with\u00a0compassion.<\/p>\n