On March 15, 2021, U.S. District Court Judge Vernon Broderick of the Southern District of New York granted Macau-based billionaire Ng Lap Seng's motion for compassionate release based on the growing COVID-19 risk in federal prisons. United States v. Ng Lap Seng, No. S5 15-CR-706 (VSB), 2021 WL 961749 (S.D.N.Y. March 15, 2021). What made the decision particularly remarkable was that Ng was soon to be fully vaccinated for COVID-19, which prosecutors argued reduced the risk of his exposure to the illness while in prison. It may be too soon to tell whether Ng's case will turn the tide of compassionate release as the vaccines became increasingly available—similar requests by scores of defendants have been denied—but it does point to possible avenues for securing compassionate release in other (non-COVID-19) scenarios.