United States v. RAYMER, 2:90-cr-00278

Defendant, age 78, has served over 35 years in federal prison and has a projected release date of 2034.
Original convictions include armed bank robberies and multiple escapes from federal custody; sentences total nearly 53 years.
Defendant filed motions for compassionate release and appointment of counsel, citing advanced age, declining health, decades in restrictive conditions, his military service-related PTSD, COVID-19 risk, and need to care for his elderly wife.
Bureau of Prisons and government acknowledged his age and health as potential extraordinary and compelling reasons but opposed reduction based on public safety and deterrence concerns.
Defendant has completed some educational and rehabilitative programming in prison.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Compassionate release: extraordinary reason	Age, health, time served, wife’s health meet criteria	Acknowledges some compelling circumstances	Court agrees age, health, time served are extraordinary
Sentence reduction under § 3553(a)	No danger to community, rehabilitation, harsh confinement	Recidivist, violent history, public must be protected	Factors weigh against reduction; risk to public remains
Conditions as release grounds	Harsh ADMAX conditions justify release	Not proper for § 3582 motion; conditions justified	Not extraordinary; result of own conduct
Appointment of counsel	Needs help litigating due to health, access to records	Not required for § 3582 and records accessible	Denied; not required or justified

Dillon v. United States, 560 U.S. 817 (Supreme Court 2010) (explaining that § 3582(c)(1)(A) is not for resentencing but narrow modification)
United States v. Goodwyn, 596 F.3d 233 (4th Cir. 2010) (finality of sentences and requirements for modifications)
United States v. Martin, 916 F.3d 389 (4th Cir. 2019) (considering post-sentencing conduct in § 3553(a) analysis)