USA v. Giles et al

IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
CENTRAL DIVISION
UNITED STATES OF AMERICA 	PLAINTIFF
v. 	CASE NO. 4:20-CR-00065-BSM
TYRON GILES 	DEFENDANT
Reg. No. 33235-009
ORDER
Tyron Giles’s pro se motion for compassionate release or sentence reduction [Doc.
No. 85] is denied because there are not extraordinary and compelling circumstances to
warrant early release. See 18 U.S.C. § 3582(c)(1)(A).
Giles was sentenced as an armed career criminal to 120 months of imprisonment for
being a felon in possession of a firearm and 132 months of imprisonment for possession with
intent to distribute methamphetamine. The sentences were run concurrently. Doc. No. 69.
Giles is seeking compassionate release or sentence reduction based on: (1) intervening
changes in sentencing law; (2) rehabilitation; and (3) harsh prison conditions. His request
is denied for five reasons.
First, compassionate release is not warranted because Giles’s violent criminal history
indicates that he is a danger to the community. PSR ¶¶ 28–48. Second, 18 U.S.C. section
922(g)(1) is properly applied to defendant even if his prior felony offenses were non-violent.
United States v. Jackson, 110 F.4th 1120, 1125 (8th Cir. 2024), cert. denied, 145 S. Ct. 2708,
221 L. Ed. 2d 970 (2025). Third, rehabilitation alone is not enough to warrant a sentence
reduction. 28 U.S.C. § 994(t). Fourth, the prison conditions that Giles complains of are not
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grounds for compassionate release. 	See United States v. Vest, 754 F. Supp. 3d 829, 838
(W.D. Mo. 2024) (citing United States v Topel, No. 18-cr-0363-BP (W.D. Mo. Feb. 16,
2022)). 	Fifth, Giles failed to exhausted his administrative remedies. 	See 18 U.S.C. §
3582(c)(1)(A). This is true because Giles failed to include any documentation indicating that
he met the exhaustion requirement.
Finally, the section 3553(a) factors were considered at sentencing and nothing in the
record supports a reduction. 	See United States v. Ram, No. 5:13-CR-50045, 2020 WL
3100837, at *3 (W.D. Ark. June 11, 2020) (no reason to revisit section 3553(a) factors when
movant has not met his burden of showing extraordinary and compelling reasons to justify
early release).
Giles’s request that he be appointed a lawyer for this motion is denied.
IT IS SO ORDERED this 2nd day of December, 2025.
________________________________
UNITED STATES DISTRICT JUDGE
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