UNITED STATES OF AMERICA v. RELONDO DEVON HALL
Criminal File No. 24-00132 (MJD)
UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA
October 31, 2025
CASE 0:24-cr-00132-MJD-ECW Doc. 56 Filed 10/31/25
Katharine T. Buzicky, Assistant United States Attorney, Counsel for Plaintiff.
Relando Devon Hall, pro se.
I. INTRODUCTION
This matter is before the Court on Defendant‘s email request for a reduction in his sentence based on family circumstances, which the Court construes as a Motion for Compassionate Release Under
II. BACKGROUND
In 2019, Hall was a member of a drug-trafficking conspiracy along with two co-conspirators who were charged in this District with various narcotics offenses. See United States v. Abari et al, Crim. No. 19-cr-103 (MJD). Hall
On May 16, 2024, Hall was charged in a single-count indictment with being a felon in possession of a firearm. (Crim. No. 24-00132, Doc. 6.) He pleaded guilty on June 27, 2024 and on October 29, 2024, was sentenced to 24 months in prison to run concurrent with the six-month revocation sentence imposed in 19-cr-103(2), followed by three years supervised release. (Doc. 40.)
Defendant is currently in the re-entry phase of his 2024 sentence, and is living in a halfway house as he transitions back into the community. (Doc. 49.) He has a projected release date of January 27, 2026. BOP, Find an inmate, https://www.bop.gov/inmateloc/ (last accessed October 30, 2025).
III. DISCUSSION
On October 27, 2025, Hall sent an email to the Court asking for early release from the halfway house to see his ill grandmother in Chicago and to help his oldest daughter cope with the challenges of recovering from fentanyl addiction while raising a family. (Doc. 49.) Hall provided very few specifics in his email. As the Government noted in its response, “Hall did not supply any evidence of request to BOP for compassionate release with his letter. As this Court knows, Hall may satisfy the exhaustion requirement of
A. Legal Framework
The court may, upon a defendant‘s motion following exhaustion of administrative remedies or the lapse of 30 days from the receipt of such a request by the warden of the defendant‘s facility, whichever is earlier,
1. Exhaustion of Administrative Remedies
Before the Court will consider a defendant‘s claims, the claims must first be presented to the BOP.
However, even if Hall were to provide evidence that he has complied with the exhaustion requirement, the Court would still find that none of Defendant‘s reasons satisfy his burden to state “extraordinary and compelling” circumstances that comport with the statute. See United States v. Avalos Banderas, 39 F.4th 1059, 1062 (8th Cir. 2022) (stating that “the inmate bears the burden to establish that compassionate release is warranted, and the district court is not required to
2. Compassionate Release
Hall first states that he wants to visit his ill grandmother who is in Chicago. This is not a reason for the Court to grant him compassionate release. To state a claim based on the need to care for grandparents, Hall needs to provide independent evidence to substantiate the claim (i.e., medical records or social-service documentation of his grandmother‘s needs). United States v. Collins, Case Nos. 15-10188-EFM, 17-10061-EFM, 2020 WL 136859, at *4 (D. Kan. Jan. 13, 2020) (“Information and documentation must be provided showing the incapacitation of the caregiver. . . .“). Hall must also show that there is no one else available to care for his grandmother. U.S.S.G. § 1B1.13(b)(3)(D). Hall‘s claim based on his grandmother‘s needs fails.
Likewise, his claim that his daughter needs help also fails for lack of documentation. Hall does not argue that his daughter has a disability or medical condition that prevents self-care, as the policy statement requires. See U.S.S.G. § 1B1.13(b)(3)(A). A prisoner‘s desire to spend time with a child, even one who is
B. Hall Still Poses a Significant Danger to the Community
Hall‘s request for a sentence reduction must also be denied because he has failed to demonstrate that he is not a danger to the safety of the community. Under U.S.S.G. § 1B1.13(a)(2), this Court must deny a sentence reduction unless it determines the defendant “is not a danger to the safety of any other person or to the community.” Here, Hall has federal convictions for conspiring to distribute fentanyl and illegally possessing a gun. He committed the latter offense while on supervision for the former, and while participating in a selective program designed to provide him extra support and rehabilitation. His current release date has been twice extended based on his non-compliance with BOP and RRC rules. Specifically, “on February 6, 2025, Mr. Hall lost 27 days of good time for Phone Abuse. On August 12, 2025, while at the RRC, Mr. Hall lost 41 days of good time for use of drugs (K2 – a synthetic cannabinoid).” (Doc. 51.) Probation notes that “[a]bsent these sanctions, Mr. Hall would have [been] released from the Bureau of Prisons on November 20, 2025.” (Id.) Accordingly, Hall put himself in his current position. Hall presents an ongoing danger to the community and this provides an additional reason to deny his motion.
C. The § 3553(a) Factors Weigh Against Hall‘s Release
Although the Court need not weigh the § 3553(a) factors because Hall has not stated any extraordinary and compelling reason for release, the Court finds that these factors provide more reasons to deny Hall‘s motion. Based on the above discussion, it is obvious that reducing Hall‘s sentence based on the evidence before the Court would not reflect the seriousness of his crime, provide just punishment, or take into account Hall‘s history and characteristics.
IV. ORDER
Based upon the files, records, and proceedings herein, IT IS HEREBY ORDERED that Defendant‘s email request for a reduction in his sentence based on family circumstances, which the Court construes as a Motion for Compassionate Release Under
Dated: October 31, 2025
s/Michael J. Davis
Michael J. Davis
United States District Court