1

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

UNITED STATES OF AMERICA,

Plaintiff, Cr. No. 15-20394

v. District Judge Arthur J. Tarnow

LANEL LOYD,

Defendant.

 /

SUPPLEMENT TO LANEL LOYD’S 

MOTION FOR COMPASSIONATE RELEASE 

Over the course of the past two months, more than 4,000 incarcerated people 

in the Bureau of Prisons (BOP) have contracted COVID-19, and at least 51 federal 

inmates have died from the disease. This is a far greater rate of infection than the 

general public. Fortunately, because of the First Step Act, federal courts have 

authority to release inmates to home confinement rather than have them suffer in 

hotbeds for infection. Under that authority, over the past month, federal courts 

around the country have been increasingly granting release to people like Lanel 

Loyd, non-violent inmates, with low risks of recidivism, who are at particular risk 

of serious illness or death from COVID-19.

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1391 Filed 05/14/20 Page 1 of 21
2

Loyd is at a heightened risk of death or serious illness from COVID-19 for 

three reasons: He immunocompromised from years of corticosteroid injections, and 

he is obese and has high blood pressure. And he is an excellent candidate for release. 

So much so, in fact, that staff at his prison, FCI Loretto, encouraged him to apply 

for home confinement. His most-recent progress report even denotes that he is an 

appropriate candidate for home confinement. These actions prompted Loyd’s family 

to make arrangements for his homecoming. Yet the BOP then abruptly changed its 

criteria for home confinement and denied Loyd’s release. 

In light of BOP’s inaction, and the potentially dire consequences if Loyd 

remains in prison, this Court should exercise its authority to grant relief under 18 

U.S.C. § 3582(c)(1)(A)(i) by releasing him and placing him on home confinement 

for the remainder of his prison sentence.

I. Procedural History

Loyd was arrested in June 2015 on charges of conspiracy to possess with 

intent to distribute controlled substances. PSR ¶ 1. He was released on bond, and 

remained on bond for almost two years until judgment was entered in March 2017. 

He complied with all terms of his supervision throughout the case. PSR ¶ 12.

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1392 Filed 05/14/20 Page 2 of 21
3

Loyd eventually pleaded guilty to conspiracy to possess with intent to 

distribute heroin. PSR ¶ 9. The underlying crimes occurred five years ago, from 

February to June 2015. PSR ¶ 6.

Loyd’s criminal history score was just one. He had only one prior conviction, 

for delivery of marijuana, for which he received a non-custodial sentence. PSR ¶ 39.

Even at the original sentencing, Loyd’s medical condition was a concern. He 

was obese and suffering from untreated hypertension. PSR ¶¶ 50, 52. He also had a 

history of cortisone shots because of constant pain in his right hip. PSR ¶ 51. This 

Court noted his physical condition as a reason for a downward variance. (See 

Statement of Reasons, at 3.)

On May 7, 2020, this Court appointed counsel after receiving a letter from 

Loyd’s family requesting compassionate release. (R. 208, Ltr., PgID 1386.) The 

letter explains that Loyd has serious medical problems putting him at a higher risk 

for severe illness or death from COVID-19, including being obese, having 

hypertension, and being immunocompromised because of his corticosteroid 

injections for hip pain. (Id.) 

Further, the letter explains that staff at FCI Loretto approached Loyd in April 

2020 to encourage him to apply for home confinement under the CARES Act, calling 

him a “good candidate.” (Id.) Loyd’s prison records confirm this account. His 

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1393 Filed 05/14/20 Page 3 of 21
4

progress report, issued on April 17, 2020, states that “Loyd has been deemed 

appropriate for Home Confinement under the criteria listed in the Attorney General’s 

COVID-19 Pandemic memorandum.” (Ex. 1, Progress Report, at 3.) Loyd signed 

paperwork to allow his release on home confinement, and at that point, Loyd’s 

family began to make plans for his release.

Yet despite this preliminary determination, the BOP then shifted its opinion 

and denied Loyd release because of new guidelines from the Attorney General 

requiring inmates to have completed 50% of their sentence before release.

Government counsel has explained that a recent BOP memorandum states that 

consideration for home confinement is prioritized for inmates who (a) have 

completed 50% of their sentence or (b) have 18 months or less to serve on their 

sentence and have completed at least 25% of their sentence. Because Loyd does not 

meet either category for prioritization, he is not currently being considered for home 

confinement, despite what BOP staff initially told him.

This account is consistent with news reports of shifting guidelines for home 

confinement in BOP, causing severe confusion among inmates and family during 

this difficult time. Walter Pavlo, The Federal Bureau Of Prisons’ “List” Has Caused 

Confusion In Courts And Prisons, Forbes, Apr. 24, 2020, 

https://www.forbes.com/sites/walterpavlo/2020/04/24/the-federal-bureau-ofCase 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1394 Filed 05/14/20 Page 4 of 21
5

prisons-list-has-caused-confusion-in-courts-and-prisons/#4e9dfc4537d4. 

Mr. Pavlo’s article describes exactly what Loyd’s family describes: several inmates 

were told they were on a “list” to be considered for home confinement, only to them 

be “notified that they were no longer eligible because they had not served 50% of 

their sentence.” Id. Yet “the BOP has no stated policy on what amount of time an 

inmate has to serve in order to be eligible for Home Confinement under the CARES 

ACT.” Id. Mr. Pavlo concludes that substantial resources and “personal pain” might

“have been avoided if the BOP just used its own policies.” Id.

II. Legal Standard for Compassionate Release

In December 2018, the First Step Act amended 18 U.S.C. § 3582(c)(1)(A)(i),

to permit sentencing judges to consider a defense motion for reduction of sentence 

based on extraordinary and compelling reasons “after the defendant has fully 

exhausted all administrative rights to appeal a failure of the Bureau of Prisons to 

bring a motion on the defendant’s behalf or the lapse of 30 days from the receipt of 

such a request by the warden of the defendant’s facility, whichever is earlier.”

Since passage of the First Step Act, courts have recognized “extraordinary 

and compelling reasons” in several circumstances. In particular, as the BOP faces a 

rapidly escalating health crisis because of COVID-19, several courts have been 

recognizing that at-risk inmates, like Loyd, meet the standard for compassionate 

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1395 Filed 05/14/20 Page 5 of 21
6

release. The pandemic alone is an extraordinary circumstance, and when face with 

an offender with pre-existing health problems rendering them vulnerable to severe 

complications from COVID-19, courts are exercising their authority to grant release 

under § 3582(c)(1)(A)(i). For examples from this district alone, see United States v, 

Saladrigas, Cr No 13-20913, ECF No. 129, Order Granting Release (E.D. Mich. 

May 13, 2020) (Borman, J.); United States v. Reddy, No. 13-CR-20358, 2020 WL 

2320093, at *4 (E.D. Mich. May 11, 2020) (Leitman, J.); United States v. Amarrah, 

No. 17-20464, 2020 WL 2220008 (E.D. Mich. May 7, 2020) (Levy, J.); United 

States v. Saad, No. 16-20197, 2020 WL 2251808, at *1 (E.D. Mich. May 5, 2020) 

(Hood, C.J.); United States v. Atwi, No. 18-20607, 2020 WL 1910152 (E.D. Mich. 

Apr. 20, 2020) (Michelson, J.); Samy v. United States, No. CR 16-20610-1, 2020 

WL 1888842 (E.D. Mich. Apr. 16, 2020) (Tarnow, J.); Miller v. United States, No. 

CR 16-20222-1, 2020 WL 1814084 (E.D. Mich. Apr. 9, 2020) (Tarnow, J.).

This is particularly true when, as here, the offender is non-violent and was 

bond-compliant.

III. This Court Should Excuse or Waive the 30-day Waiting Period.

Section 3582(c)(1)(A)(i) generally requires exhaustion of administrative 

remedies. Loyd has asked for home confinement under the CARES Act (at the 

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1396 Filed 05/14/20 Page 6 of 21
7

urging of staff at FCI Loretto) and was already denied. On May 11, 2020, he also 

asked for compassionate release, and he has yet to receive a response.

Because the BOP has already rejected Loyd as a candidate for home 

confinement, this Court should excuse any further need for Loyd to exhaust 

remedies. Judge Leitman explained, when granting release to a person who had been 

reviewed for (and denied) home confinement but had not fully exhausted 

administrative remedies, “the purpose behind the exhaustion requirement of 

§ 3582(c)(1)(A) – providing notice to the BOP of a prisoner’s claim for release and 

giving the BOP more than one opportunity to review the claim before the inmate 

brings a motion – has already been served by [the defendant]’s Petition and the 

BOP’s recent review of her claim.” Reddy, 2020 WL 2320093, at *4. This Court 

should likewise waive exhaustion because the BOP has been made aware of Loyd’s 

request for early release to home confinement—in light of his medical problems and 

COVID-19—and failed to act.

Moreover, waiting to exhaust would unduly prejudice Loyd, since waiting for 

the BOP could result in disastrous consequences if he were to contact COVID-19. 

For that reason, this Court has excused the exhaustion requirement in similar 

circumstances. See Samy v. United States, No. CR 16-20610-1, 2020 WL 1888842, 

at *2 (E.D. Mich. Apr. 16, 2020) (waiving 30-day waiting period where exhaustion 

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1397 Filed 05/14/20 Page 7 of 21
8

would be futile and unduly prejudicial); Miller v. United States, No. CR 16-20222-

1, 2020 WL 1814084 (E.D. Mich. Apr. 9, 2020) (same). This Court’s decisions are 

consistent with others in this district and around the country. Reddy, 2020 WL 

2320093, at *4; Saad, 2020 WL 2251808, at *2 (excusing exhaustion for 

incarcerated person at Milan); Atwi, 2020 WL 1910152, at *3 (same); United States 

v. Coles, No. 18-CR-20254, 2020 WL 1899562, at *4 (E.D. Mich. Apr. 17, 2020) 

(Drain, J.) (excusing exhaustion for incarcerated person at Elkton). The Court should 

take the same approach here

IV. Extraordinary and Compelling Reasons Warrant Release

Loyd’s pre-existing health conditions, combined with the global pandemic, 

warrant compassionate release. In particular, Loyd’s current health conditions and 

incarceration during this pandemic “substantially diminishes the ability of the 

defendant to provide self-care within the environment of a correctional facility and 

from which [he] is not expected to recover.” U.S.S.G. § 1B1.13, cmt. n. 1(A)(ii); 

Reddy, 2020 WL 2320093, at *4; Amarrah, 2020 WL 2220008, at *6. He also 

presents “Other Reasons” under U.S.S.G. § 1B1.13, cmt. n. 1(D), warranting

compassionate release, Miller, 2020 WL 1814084, at *3, because while the COVID19 pandemic is devastating in every region it invades, prison populations are subject 

to heightened vulnerability.

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1398 Filed 05/14/20 Page 8 of 21
9

A. The COVID-19 pandemic is ravaging the BOP. 

BOP’s statistics show COVID-19’s devastation: 

• 4,173 inmates have contracted the disease (1,353 of these inmates 

recovered);

• 548 BOP staff have contracted the disease (282 of these staff members 

recovered); and

• at least 51 inmates died from it.

Further, the outcry has continued, even from BOP staff, about how poorly this 

crisis is being handled by BOP. Staff have filed an OSHA complaint alleging BOP 

has “failed to introduce workplace controls to mitigate or prevent exposure or further 

exposure to the virus,” including at Loyd’s facility.1 More recently, after the death 

of a young woman who recently gave birth at FMC Carswell, a whistleblower 

complaint from the BOP staff union for Carswell came to light alleging that the BOP 

was knowingly misleading the American public about conditions in federal prisons.

Keegan Hamilton, EXCLUSIVE: Whistleblower Warned of Coronavirus Danger in 

Prison Where a Woman Just Died After Giving Birth, Vice News, Apr. 29, 2020, 

 1 See OSHA Complaint, https://www.afge.org/globalassets/documents/generalreports/

coronavirus/4/osha-7-form-national-complaint.pdf. This complaint was filed in March 

when there were 28 confirmed inmate cases, 24 confirmed staff cases, and one inmate 

death. The situation is exponentially worse now.

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1399 Filed 05/14/20 Page 9 of 21
10

https://www.vice.com/en_us/article/pke7z8/exclusive-whistleblower-warned-ofcoronavirus-danger-in-prison-where-a-woman-just-died-after-giving-birth. 

This Court has authority to prevent this type of “playing roulette with people’s 

lives” by replacing Loyd’s remaining term with home confinement. Timothy 

Williams, et al., ‘Jails Are Petri Dishes’: Inmates Freed as the Virus Spreads Behind 

Bars, NY TIMES, Mar. 31, 2020, https://www.nytimes.com/2020/03/

30/us/coronavirus-prisons-jails.html (quoting NYC Chief Federal Defender David 

Patton).

B. Loyd’s health places him at high risk of death or serious illness.

Loyd squarely fits the definition of an individual who has a higher risk of 

falling severely ill or dying from COVID-19, for three reasons:

One: Obesity. Loyd is obese, putting him at high risk of death from COVID19. Loyd lost some weight in prison, and in December 2019, he had a BMI of 38. 

(Ex. 5, Medical Record, at 3.) But Loyd reports that he is currently 6’1” and 308

pounds, giving him a BMI over 40. According to the Centers for Disease Control 

and Prevention, anyone with a BMI of 40 or higher are at higher risk for severe 

illness from COVID-19. CDC.gov, Coronavirus Disease 2019, 

https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/groups-athigher-risk.html. Other courts have noted a person’s BMI over 40, along with other 

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1400 Filed 05/14/20 Page 10 of 21
11

factors, in granting compassionate release in light of the COVID-19 pandemic. See 

United States v. Dawson, No. 18-40085-HLT, 2020 WL 1812270, at *5 (D. Kan. 

Apr. 9, 2020) (“The court finds that Mr. Dawson has established that his obesity puts 

him at an increased risk for severe illness if he were to contract COVID-19, which 

weighs in favor of finding exceptional reasons.”); United States v. Zukerman, No. 

16 CR. 194 (AT), 2020 WL 1659880, at *5 (S.D.N.Y. Apr. 3, 2020) (noting that 

movant’s obesity placed him “at higher risk for severe illness from COVID-19”).

Two: High Blood Pressure. Loyd also is at higher risk of death or serious 

illness from COVID-19 because of his hypertension. See American Heart 

Association Guidance, https://newsroom.heart.org/news/what-people-with-highblood-pressure-need-to-know-about-covid-19 (explaining that people with high 

blood pressure “may face an increased risk for severe complications if they get the 

virus”). Loyd is prescribed daily amlodipine for his hypertension.

Notably, many courts, including at least four in this district, “have identified 

hypertension as an underlying medical condition that renders a prisoner higher-risk, 

weighing against continued detention during the COVID-19 pandemic.” United 

States v. Sanders, No. 19-cr-20288, ECF No. 35, PgID 202–03 (E.D. Mich. Apr. 17, 

2020) (citing United States of America v. Patino, No. 18-cr-20451, 2020 WL 

1676766, at *2 (E.D. Mich. Apr. 6, 2020) (“Mr. Patino is at high risk due to stage 3 

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1401 Filed 05/14/20 Page 11 of 21
12

chronic kidney disease and hypertension, and his age (63 years old).”); United States 

v. Doshi, No. 13-cr-20349, 2020 WL 1527186, at *1 (E.D. Mich. Mar. 31, 2020) 

(recommending that prisoner with hypertension and diabetes be placed in home 

confinement); Basank v. Decker, No. 20 Civ. 2518 (AT), 2020 WL 1481503, at *3 

(S.D.N.Y. Mar. 26, 2020) (releasing detainee with hypertension from civil 

immigration detention due to COVID-19 concerns).

Just today, Judge Roberts granted bond release to another person with 

hypertension in light of COVID-19. United States v. Bray, Cr. No. 19-20216, ECF 

No. 164, PgID 627-28 (E.D. Mich. May 14, 2020). She explained that “new studies 

identify an increased risk of death from the virus for individuals with hypertension.”

Id. (citing Deborah J. Nelson, Blood-pressure drugs are in the crosshairs of COVID19 research, REUTERS (Apr. 23, 2020), https://www.reuters.com/article/us-healthconoravirus-blood-pressureins/blood-pressure-drugs-are-in-the-crosshairs-ofcovid-19-research-idUSKCN2251GQ; Shiki Garg, Lindsay Kim, et al., 

Hospitalization Rates and Characteristics of Patients Hospitalized with LaboratoryConfirmed Coronavirus Disease 2019 – COVID-NET, 14 States, March 1–30 2020, 

Morbidity and Mortality Weekly Report, CDC (Apr. 8, 2020), 

https://www.cdc.gov/mmwr/volumes/69/wr/mm6915e3.htm). Loyd’s chronic 

hypertension thus puts him at particular risk.

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1402 Filed 05/14/20 Page 12 of 21
13

.

Three: Immunocompromised. Loyd receives injections of corticosteroids for 

his hip pain. His hip pain is so severe that he was recently issued a cane for mobility, 

and he has used corticosteroids to manage his pain for several years. (Exs. 4, 5, 

Medical Records.) In May and June 2019, he was transported for treatment to the 

Center for Orthopedics and Sports Medicine at Indiana Regional Medical Center in 

Pennsylvania. (Ex. 6, Medical Center Record.) The doctor there explained that Loyd 

had a slipped hipbone (“capital femoral epiphysis”) that “was never treated 

properly,” and now he “has progress to severe osteoporotic arthritis of the hip.” (Id. 

at 4.) He has difficulty tying his shoes and getting out of bed, and he experiences 

occasional “locking up” of his right hip. (Ex. 5, Medical Records.)

The CDC recognizes that the “prolonged use of corticosteroids and other 

immune weakening medications” is a risk factor for death or serious illness from 

COVID-19. CDC.gov, Coronavirus Disease 2019, People Who Are at Higher Risk 

for Severe Illness, https://www.cdc.gov/coronavirus/2019-ncov/need-extraprecautions/people-at-higher-risk.html. For that reason, at least one court has relied 

in part on a person’s use of corticosteroids in granting compassionate release in the 

wake of the COVID-19 pandemic. United States v. Edwards, No. 6:17-CR-00003, 

2020 WL 1650406, at *5 (W.D. Va. Apr. 2, 2020).

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1403 Filed 05/14/20 Page 13 of 21
14

C. Conditions at FCI Loretto warrant relief.

Although there are no confirmed cases at FCI Loretto, that does not mean that 

Loyd is not at an extraordinary risk. Judge Levy recently granted release to another 

inmate at Loretto—who was 45 years old and 21 months into a 60-month sentence—

suffering from pre-existing conditions making him susceptible to COVID-19. 

Amarrah, 2020 WL 2220008, at *3. Judge Levy quoted Mr. Amarrah’s description 

of conditions at Loretto, and she noted that the government “does not dispute this 

description of current conditions at FCI Loretto”:

[I]nmates currently “eat, sleep, and interact with each other in a 

confined space, making it easier for the virus to spread once 

introduced. Inmates are still being transferred between facilities. 

Although they are screened for symptoms, they are not tested for the 

virus, leaving potentially asymptomatic individuals to spread the virus 

to others. While inmates are being subjected to mandatory quarantine, 

they are still not provided basic protections from the virus in the 

facilities. Inmates must purchase their own soap. Hand sanitizer is 

contraband. In low security facilities, inmates are being quarantined 

with their own unit, as opposed to individual cells, preventing them 

from complying with social distancing recommendations. 

Id. at *3.

The court then addressed the government’s argument that the lack of positive 

COVID-19 tests undermines the argument that there are extraordinary and 

compelling circumstances warranting release:

FCI Loretto does not have any confirmed cases, and the United States 

argues that this should be a compelling factor in the Court’s analysis. 

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1404 Filed 05/14/20 Page 14 of 21
15

However, it is unclear whether or to what extent FCI Loretto is testing 

the existing inmate population, and the United States’ brief is silent on 

this issue. Indeed, when the Court questioned counsel for the United 

States during oral argument, he responded that he “d[id] not know” how 

or if FCI Loretto was conducting COVID-19 testing of its detained 

population.

Zero confirmed COVID-19 cases is not the same thing as zero COVID19 cases. The Bureau of Prisons recently discovered this when it found 

that 70 percent of the inmates it tested were positive for the disease. See 

Sadie Gurman, More Than 70% of Inmates Tested in Federal Prisons 

Have Coronavirus, The Wall Street Journal (Apr. 30, 2020), 

https://www.wsj.com/articles/more-than-70-of-inmates-tested-infederal-prisons-have-coronavirus-11588252023 (noting that “prison 

officials expect [this number] to rise as they expand testing with a focus 

on the hardest-hit facilities”). The Southeast Regional Vice President 

of the Council of Prison Locals referred to “the inside of a[ prison] 

institution” as a “little petri dish ... a life and death situation [that prison 

officials then take] home to our families.” Id. This disease spreads 

asymptomatically, which means the Court and the prison system can 

take no comfort in a lack of confirmed cases, and all parties should be 

deeply concerned by the lack of universal testing of inmates and staff. 

See How COVID-19 Spreads, CDC (Apr. 3, 2020).

For these reasons, unless and until FCI Loretto implements a universal 

testing regimen, the Court gives no weight to the zero “confirmed” 

COVID-19 cases statistic—particularly because BOP is housing 

detainees together, because the United States could not give the Court 

any information regarding current testing practices, and because basic 

disinfecting tools such as soap and hand sanitizer are not universally 

provided to the population. To the contrary, the Court finds that the lack 

of testing aggravates its concerns about Defendant’s likelihood to 

contract COVID-19 while in federal custody. Accordingly, the Court 

finds that extraordinary and compelling circumstances warrant a 

reduction of Defendant’s sentence. The current conditions of 

Defendant’s confinement at FCI Loretto, which Defendant has no 

power to alter, expose him to a substantial risk of contracting COVID19. And Defendant’s numerous medical conditions render him 

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1405 Filed 05/14/20 Page 15 of 21
16

substantially likely to suffer a dire outcome should he contract the virus. 

Together, these factors require the Court to conclude that Defendant is 

suffering from a serious physical or medical condition that 

“substantially diminishes the ability of the defendant to provide selfcare within the environment of a correctional facility and from which 

[he] is not expected to recover.” 18 U.S.C. § 3582(c)(1)(A)(i).

Id. at *6 (broken hyperlink omitted). This analysis applies with equal force to Loyd, 

and this Court should find, as Judge Levy did with Mr. Amarrah, that Loyd’s 

situation rises to the level of extraordinary and compelling circumstances warranting 

release to home confinement.

It is also notable that Loyd was told by staff at Loretto that he was a good 

candidate for home confinement, only to have that position undermined by 

contradictory standards issued by BOP. The Legislative Committee of the Federal 

Public & Community Defenders recently criticized this trend in a letter to Members 

of Congress, explaining that “[c]onfused and contradictory standards have cruelly 

resulted in situations where families, informed that a loved one will be transferred 

to the relative safety of home, are turned away when they arrive at prison gates, and 

told their loved one is no longer eligible for home confinement.” (Ex. 7, FDO Letter, 

at 6.) They also expressed concern that “these confused standards will 

disproportionately harm racial and ethnic minorities.” (Id.)

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1406 Filed 05/14/20 Page 16 of 21
17

D. Other § 3553(a) factors favor release.

Loyd is not a danger if released on home confinement. He does not have a 

violent history. He complied with bond for almost two years during the pendency of 

his case, and this Court permitted him self-surrender.

Loyd has maintained clean conduct for almost two years. He has only one 

disciplinary action, from June 2017, two months after he entered custody, for

“giving/accepting money.” He lost 15 days of visiting for the offense. By way of 

explanation, Loyd incurred this sanction for using another inmate’s ticket to take a 

picture in the visiting room, an action he had failed to understand was against prison 

policies. He has had no disciplinary actions since then, and is scored by BOP as a 

“minimum risk” of recidivism. (Ex. 3, Inmate PATTERN Score.) His disciplinary is 

not an indication that he is dangerous if released, especially given that BOP staff 

initially designated him as “appropriate for Home Confinement.” (Ex. 1, Progress 

Report, at 3.)

Loyd has consistently engaged in programming while in prison, taking more 

than 20 classes. His program review comments, “Great programming.” (Ex. 2, 

Program Review at 2.) The courses he has taken include the non-residential drug 

abuse program, parenting classes, and vocational skills. In 2018, he received his 

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1407 Filed 05/14/20 Page 17 of 21
18

certification in HVAC heat pumps. He works as an orderly, and has paid his financial 

obligations to the Court.

As indicated in nine attached letters, Loyd has very strong family support and 

a team of people waiting to help him re-enter society and become a productive 

citizen. His wife Shawneta Loyd explains that the couple has two children together, 

and Loyd has four boys total, and that they all love him. (Ex. 8, Shawneta Letter.) 

She attests to seeing a change in Loyd and says he sees “the wrong in his actions and 

hopes and prays for a chance to reunite with his children and prove that this time 

away has changed him into a better human being.” (Id.)

Other family members also write in support. Loyd’s sister-in-law, Novella

Dumas, explains how she has personally witnessed significant growth in Loyd, and 

how he has embraced opportunities to grow in prison. (Ex. 9, Dumas Letter.) She 

notes, “Every chance he gets, he can be heard telling his children, nieces, and 

nephews the importance of staying in school and staying steer away from street life.” 

(Id.) He recognizes his own mistakes and is striving to be a positive influence on 

others. (Id.) She concludes, “With the strong family support and Lanel’s selfdetermination, he has a low risk of recidivism, and will be a positive, productive 

human being in society.” (Id.)

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1408 Filed 05/14/20 Page 18 of 21
19

Additionally, Loyd’s father-in-law and mother-in-law confirm Ms. Dumas’s 

account and explain how the family prepared for his release after BOP initially 

informed him about home confinement. (Exs. 10, 11, Taylor and Rev. Taylor 

Letters.) His mother-in-law writes: “After hearing from Lanel that the prison 

officials advised him that he was a good candidate for home confinement, and 

encouraged him to apply, we began preparing to bring him into a safe secure home 

environment, due to the threat of Cov-19, which places his health at risk of serious 

illness or death.” (Ex. 11, Rev. Taylor Letter.) She adds: “Lanel has proven himself 

over the three years of incarceration that he been reformed and does not pose a 

danger to the community.” (Id.)

Additionally, five other family members and friends write to express support. 

(Exs. 12-16.) James Dumas writes that he talks to Loyd every week on the BOP 

email system and that Loyd calls frequently. (Ex. 12, James Dumas Letter.) He says 

Loyd loves his children and would not waste the opportunity to be with them again. 

(Id.) Nickolas Philips explains how Loyd has mentored him over the years. (Ex. 13,

Philips Letter.) Whitney Kimble explains that Loyd has “a solid support system of 

close family and friends, four sons and countless resources for self-improvement at 

his disposal.” (Ex. 14, Kimble Letter.)

This Court should not hesitate to release Loyd to home confinement.

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1409 Filed 05/14/20 Page 19 of 21
20

Conclusion

Lanel Loyd respectfully requests compassionate release.

Respectfully Submitted,

FEDERAL DEFENDER OFFICE

s/Benton C. Martin 

Benton_Martin@fd.org

613 Abbott St., Suite 500

Detroit, MI 48226

Phone: 313-967-5832

Dated: May 14, 2020

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1410 Filed 05/14/20 Page 20 of 21
21

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

UNITED STATES OF AMERICA,

Plaintiff, Cr. No. 15-20394

v. District Judge Arthur J. Tarnow

LANEL LOYD,

Defendant.

 /

CERTIFICATE OF SERVICE

I certify that on May 14, 2020, I filed the foregoing paper with the through the 

court’s electronic docketing system, which will send notification to opposing 

counsel of record. 

/s/Benton C. Martin

Case 2:15-cr-20394-AJT-RSW ECF No. 211, PageID.1411 Filed 05/14/20 Page 21 of 21