United States v. RAYMER, 2:90-cr-00293

The defendant, a 78-year-old veteran, is serving an aggregate federal sentence of nearly 53 years, with a projected release date in 2034.
His convictions stem from bank robberies, multiple escapes from federal custody, and firearms violations; he has been incarcerated almost continually since 1982.
Defendant filed pro se motions for compassionate release and appointment of counsel, citing advanced age, deteriorating health, lengthy incarceration, veteran status, Covid-19 risk, prison conditions, and his elderly wife's needs.
The government opposed on public safety and deterrence grounds, but conceded that age and declining health were extraordinary and compelling under current Sentencing Commission standards.
The court considered supplemental filings and the defendant's post-incarceration rehabilitation efforts but focused on 18 U.S.C. § 3553(a) factors.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Compassionate release standards	Age, health, time served, family needs meet criteria	Defendant’s recidivism and danger outweigh factors	Extraordinary reasons exist, but § 3553(a) factors oppose release
Harsh prison conditions as basis	Long-term restrictive custody compels relief	Such conditions are not grounds for release	Not an extraordinary reason; necessary due to escapes
Risk from Covid-19	Age/health heighten Covid risk in custody	BOP care and facility conditions mitigate risk	No compelling Covid risk shown
Appointment of counsel	Needs legal help due to health and complexity	Defendant capable pro se, has records and filings	No right or need for counsel

Dillon v. United States, 560 U.S. 817 (2010) (discusses § 3582(c)(1)(A) as a modification—not resentencing—procedure)
United States v. Goodwyn, 596 F.3d 233 (4th Cir. 2010) (finality of sentences and scope of modifications under federal law)
United States v. Martin, 916 F.3d 389 (4th Cir. 2019) (courts may consider post-sentencing rehabilitation for § 3582 motions)