United States v. Isaac Loggins, Jr., 966 F.3d 891

In 2002, Isaac Loggins Jr. pleaded guilty to three Hobbs Act robberies (18 U.S.C. § 1951) and two counts of using a firearm in relation to those robberies (18 U.S.C. § 924(c)).
The district court sentenced Loggins to 353 months’ imprisonment, including consecutive sentences for the two § 924(c) convictions.
After the First Step Act (which permits prisoners to move for compassionate release under 18 U.S.C. § 3582(c)(1)(A)), Loggins moved in July 2019 for a sentence reduction based on “extraordinary and compelling” circumstances.
The Sentencing Commission policy statement (USSG § 1B1.13) commentary still refers to motions by the BOP Director and lists limited grounds; Loggins argued the First Step Act allows courts to consider other reasons (including changes to § 924(c) sentencing and his rehabilitation).
The district court acknowledged Loggins’s arguments, found the change to § 924(c) sentencing nonretroactive, commended his rehabilitation but deemed it insufficient, and denied compassionate release.
The Eighth Circuit affirmed, concluding the district court reasonably exercised its broad discretion and that it considered Loggins’s arguments even if it did not address every point in separate detail.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district courts are bound by USSG § 1B1.13 commentary limiting relief to BOP-initiated motions	Loggins: First Step Act allows courts to consider reasons beyond the commentary and to grant motions filed by defendants	Government/District Court: Policy statement still governs; courts should follow commentary (or at least defer to it)	Court: Need not decide whether statute supersedes commentary; affirmed because district court considered Loggins’s arguments and denied relief on the merits
Whether changes in § 924(c) sentencing (anti-stacking) are an extraordinary and compelling reason for release	Loggins: New law reducing "stacking" supports release	Government: Change in law is not retroactive and thus does not justify relief	Court: Change is nonretroactive and does not amount to extraordinary and compelling reasons for release
Whether post‑sentencing rehabilitation (alone or combined with change in law) warrants compassionate release	Loggins: Rehabilitation and legal changes together justify reduction	Government: Rehabilitation is commendable but not by itself extraordinary and compelling	Court: District court properly considered rehabilitation and reasonably concluded it was insufficient; no need to address every argument separately

United States v. Johnson, 619 F.3d 910 (8th Cir. 2010) (district court need not make a specific rejoinder to every circumstance cited by a movant)