USA v. Steward

1
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF ARKANSAS
FAYETTEVILLE DIVISION
UNITED STATES OF AMERICA 	PLAINTIFF
V. 	CASE NO. 5:15-CR-50072
RANDALL STEWARD 	DEFENDANT
ORDER
Before the Court is Defendant Randall Steward’s pro se Motion for Early Release
(Doc. 60). The Court finds that no response from the Government is necessary and that
the matter is ripe for consideration.
On September 23, 2016, the Court sentenced Mr. Steward to 151 months of
imprisonment, five years of supervised release, a $100.00 special assessment, and a
$2,400.00 fine for the crime of sex trafficking of a minor. Mr. Steward’s Motion filed today
advises the Court that his case manager at the Bureau of Prisons requested that Mr.
Steward be placed in a halfway house back in January, but all facilities were either full or
could not accept him for whatever reason. Mr. Steward now asks for the Court’s help in
granting early release or sentencing him to serve the remainder of his sentence in home
confinement. His Motion also details the many accomplishments he has achieved while
in 	prison, 	including 	successfully 	completing 	his 	G.E.D., 	staying 	clear 	of 	drugs,
disassociating from all gang affiliations, maintaining two jobs, and receiving certifications
in HVAC and safe food handling.
The Court commends Mr. Steward on the positive steps he has made in prison to
better his life and encourages him to continue on his path of sobriety, health, and
productivity. Unfortunately, however, the Court is without authority to grant him the relief
he seeks for two reasons.
Case 5:15-cr-50072-TLB Document 61 Filed 04/02/25 Page 1 of 2 PageID #:
<pageID>

2
First, 	post-conviction 	rehabilitation 	does 	not 	provide 	sufficient 	grounds 	for
compassionate early release. See 28 U.S.C. § 994(t) (“Rehabilitation of the defendant
alone shall not be considered an extraordinary and compelling reason.”); U.S.S.G.
§ 1B1.13 cmt. n.3 (“Pursuant to 28 U.S.C. § 994(t), rehabilitation of the defendant is not,
by itself, an extraordinary and compelling reason for purposes of this policy statement.”).
Second, only the Bureau of Prisons can make the decision to place a prisoner on home
confinement or in a residential re-entry center. See United States v. Houck, 2 F.4th 1082,
1085 (8th Cir. 2021) (finding, in compassionate release context, that “[b]ecause [18
U.S.C. § 3624(c)(2) and the CARES Act] give authority to place a prisoner in home
confinement to the Director of the BOP, not the district court, the district court correctly
held that it did not have authority to change [the prisoner's] place of imprisonment to home
confinement under § 3624(c)(2)”).
Moreover, even if the Court were authorized to release Mr. Steward to home
confinement, it would still defer to the Bureau of Prisons, which has more closely followed
his behavior and progress while incarcerated and is in a superior position to evaluate him
and make the appropriate determination as to his eligibility for this program.
Finally, if the matter were properly before it, the Court would also need to consider
the factors under 18 U.S.C. § 3553(a), which might not weigh in favor of early release.
IT IS THEREFORE ORDERED that Defendant Randall Steward’s pro se Motion
for Early Release (Doc. 60) is DENIED.
IT IS SO ORDERED on this 2 nd day of April, 2025.
TIMOTHY L. BROOKS
UNITED STATES DISTRICT JUDGE
Case 5:15-cr-50072-TLB Document 61 Filed 04/02/25 Page 2 of 2 PageID #:
<pageID>