UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

UNITED STATES OF AMERICA,

Plaintiff, CRIMINAL NO. 06-cr-20465

v. HON. NANCY G. EDMUNDS

RONALD HATMAKER,

Defendant.

 

GOVERNMENT’S RESPONSE OPPOSING DEFENDANT’S 

MOTION FOR COMPASSIONATE RELEASE 

UNDER SECTION 3582(c)(1)(A)

Defendant Ronald Hatmaker, a former Detroit Chapter President

of a violent outlaw Motorcycle gang, the Detroit Highwaymen 

Motorcycle Club, was convicted after a guilty plea to being part of a 

RICO enterprise. He received a well-deserved sentence of 170 months 

(reduced from an original 188 months) imprisonment, based upon his 

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overall conduct and the conduct of the co-conspirators he knowingly 

joined with, and whose activities he directed. 

Hatmaker began serving his current sentence on September 27, 

2012. He now moves for compassionate release under 18 U.S.C. 

§ 3582(c)(1)(A). He cites various medical conditions in support of his 

motion, including “heart trouble,” hypertension, and “heart disease.” 

His motion should be denied.

Hatmaker does not satisfy the statutory requirements for

compassionate release. For starters, because he has not met the 

mandatory exhaustion requirement in 18 U.S.C. § 3582(c)(1)(A), the 

Court is barred from addressing his argument on the merits. United 

States v. Alam, 960 F.3d 831 (6th Cir. 2020). Hatmaker also does not 

satisfy the substantive requirements. “[T]he mere existence of Covid-19 

in society and the possibility that it may spread to a particular prison 

alone cannot independently justify compassionate release.” United 

States v. Raia, 954 F.3d 594, 597 (3d Cir. 2020). The government agrees 

that Hatmaker’s increased risk of severe complications from Covid-19 

based on his heart disease qualifies as “extraordinary and compelling

reasons” for release. But the § 3553(a) factors—which the Court must 

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also consider under § 3582(c)(1)(A)—do not support release because he 

is dangerous and has a long remaining sentence to serve.

The Bureau of Prisons has also taken significant steps to protect 

all inmates, including Hatmaker from Covid-19. Since January 2020, 

the Bureau of Prisons has implemented “a phased approach 

nationwide,” implementing an increasingly strict protocol to minimize 

the virus’s spread in its facilities. Wilson v. Williams, 961 F.3d 829, 

833–34 (6th Cir. 2020). The Bureau of Prisons has also received 75,395

doses of the Covid-19 vaccine as of 03/10/2021 and is distributing the 

vaccine to its staff and inmates as quickly as it is received by each 

institution. See CDC Covid-19 Vaccine Tracker and BOP COVID-19 

Vaccination Implementation. The Bureau of Prisons also continues to 

assess its entire population to determine which inmates face the most

risk from Covid-19, pose the least danger to public safety, and can 

safely be granted home confinement. And the Bureau of Prisons has 

assessed its entire population to determine which inmates face the most

risk from Covid-19, pose the least danger to public safety, and can

safely be granted home confinement. Especially given the Bureau of 

Prisons’ efforts—and “the legitimate concerns about public safety” from 

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releasing inmates who might “return to their criminal activities,” 

Wilson, 961 F.3d at 845—the Court should deny Hatmaker’s motion for 

compassionate release. 

Background

Hatmaker, a former Detroit Chapter President of the notorious 

Highwaymen Motorcycle Gang pleaded guilty to Ct.2, 18 U.S.C. § 

1962(d) – RICO Conspiracy.

Having found Hatmaker guilty of Count Two, at sentencing, the 

Court held him responsible for various racketeering acts committed by 

members of the RICO enterprise:

Act 02 – Conspiracy to Murder Gerald Deese

Act 03 – Extortion of Anthony Barton

Act 04 – Armed Robbery of Steve Peet

Act 09 – Conspiracy to Distribute Cocaine

Act 11 – Conspiracy to Distribute Controlled Substances

Act 12 – Conspiracy to Commit Murder of Doug Burnett

With an advisory Guideline Range of 244 months imprisonment, 

the Court sentenced Hatmaker to188 months (later reduced to 170 

months) in prison. 

Hatmaker began serving his prison sentence on September 27,

2012 and is currently incarcerated at Federal Correctional Institution 

(FCI) Hazelton. He is 62 years old, and his projected release date is 

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12/10/2024. Hatmaker has moved for compassionate release, citing his 

medical conditions, Heart Disease (unstable angina and aortic stenosis) 

and hypertension, and the Covid-19 pandemic. According to BOP 

records, Hatmaker first requested compassionate release from the 

warden on March 9, 2021. He therefore had not exhausted his 

administrative remedies when he filed his motion in January 2021.

Argument

I. The Bureau of Prisons has responded to Covid-19 by

protecting inmates and increasing home confinement. 

A. The Bureau of Prisons’ precautions have mitigated 

the risk from Covid-19 within its facilities. 

The Bureau of Prisons has reacted quickly to confront Covid-19’s 

spread within its facilities. Wilson v. Williams, 961 F.3d 829, 833–34 

(6th Cir. 2020). For over almost a decade, the Bureau of Prisons has 

maintained a detailed protocol for responding to a pandemic. Contrary 

to Hatmaker’s arguments (ECF No. 3061, Motion, PageID.23215), and 

consistent with its protocol, the Bureau of Prisons began planning for 

Covid-19 in January 2020, and has repeatedly revised its plan. Wilson, 

961 F.3d at 833–34. By this point, the Court is aware of the Bureau of 

Prisons’ efforts. BOP Covid-19 Modified Operations Website.

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Like all other institutions, penal and otherwise, the Bureau of 

Prisons has not been able to eliminate the risks from Covid-19

completely, despite its best efforts. But the Bureau of Prisons’ measures 

will help federal inmates remain protected from Covid-19 and ensure 

that they receive any required medical care during these difficult times.

B. The Bureau of Prisons is increasing the number of 

inmates who are granted home confinement. 

The Bureau of Prisons has also responded to Covid-19 by

increasing the placement of federal prisoners in home confinement.

Legislation temporarily permits the Bureau of Prisons to “lengthen the 

maximum amount of time for which [it] is authorized to place a prisoner 

in home confinement” during the Covid-19 pandemic. CARES Act 

§ 12003(b)(2), Pub. L. No. 116-136, 134 Stat. 281, 516 (Mar. 27, 2020). 

The Attorney General has also issued two directives, ordering the 

Bureau of Prisons to use the “various statutory authorities to grant 

home confinement for inmates seeking transfer in connection with the 

ongoing Covid-19 pandemic.” (03-26-2020 Directive to BOP, at 1; accord

04-03-2020 Directive to BOP, at 1). The directives require the Bureau of 

Prisons to identify the inmates most at risk from Covid-19 and “to 

consider the totality of circumstances for each individual inmate” in 

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deciding whether home confinement is appropriate. (03-26-2020 

Directive to BOP, at 1). 

The Bureau of Prisons’ efforts on this point are not hypothetical. 

Currently, the Bureau of Prisons has 7,517 inmates on home 

confinement, and the total number of inmates placed in home 

confinement from March 26, 2020 to the present (including inmates who 

have completed service of their sentence) is 22,539 BOP Coronavirus 

FAQs. As the Sixth Circuit stressed, these efforts show that “[t]he 

system is working as it should”: “A policy problem appeared, and policy 

solutions emerged.” United States v. Alam, 960 F.3d 831, 836 (6th Cir. 

2020). 

This policy solution is also tailored to the realities of the Covid-19 

pandemic. The Bureau of Prisons, after all, cannot open its facilities’ 

gates indiscriminately and unleash tens of thousands of convicted 

criminals, en masse. See id. It must focus on the inmates who have the 

highest risk factors for Covid-19 and are least likely to engage in new 

criminal activity. This is true not just to protect the public generally, 

but to avoid the risk that a released defendant will bring Covid-19 back 

into the jail or prison system if he violates his terms of release or is 

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caught committing a new crime. See 18 U.S.C. § 3624(g)(5); 34 U.S.C. 

§ 60541(g)(2).

The Bureau of Prisons must also balance another important 

consideration: how likely is an inmate to abide by the CDC’s socialdistancing protocols or other Covid-19-based restrictions on release? 

Many inmates—particularly those who have been convicted of serious 

offenses or have a lengthy criminal record—been already proven

unwilling to abide by society’s most basic norms. It is thus important to 

evaluate “how . . . released inmates would look after themselves,” 

Wilson, 961 F.3d at 845, including whether a particular inmate would 

adhere to release conditions and social-distancing protocols during the 

pandemic. If a prisoner would be unlikely to take release conditions or

Covid-19 precautions seriously, for instance, he would also be far more 

likely than the general public to contract and spread Covid-19 if 

released. 

Finally, the Bureau of Prisons’ home-confinement initiative allows 

it to marshal and prioritize its limited resources for the inmates and 

circumstances that are most urgent. For any inmate who is a candidate 

for home confinement, the Bureau of Prisons must first ensure that his 

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proposed home-confinement location is suitable for release, does not 

place him at an even greater risk of contracting Covid-19, and does not 

place members of the public at risk from him. It must assess 

components of the release plan, including whether the inmate will have 

access to health care and other resources. It must consider myriad other 

factors, including the limited availability of transportation right now

and the probation department’s reduced ability to supervise inmates 

who have been released. All of those decisions require channeling

resources to the inmates who are the best candidates for release. 

Those types of system-wide resource-allocation decisions are 

difficult even in normal circumstances. That is why Congress tasked the 

Bureau of Prisons to make them and has not subjected the decisions to 

judicial review. 18 U.S.C. § 3621(b) (“Notwithstanding any other 

provision of law, a designation of a place of imprisonment under this 

subsection is not reviewable by any court.”); United States v. Patino, 452 

F.Supp.3d 705, 712 (E.D. Mich. 2020) (“[A]s a general rule, the Court 

lacks authority to direct the operations of the Bureau of Prisons.”). It is 

especially true now, given the Bureau of Prisons’ substantial and 

ongoing efforts to address the Covid-19 pandemic.

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C. The Bureau of Prisons is receiving the Covid-19 

vaccine and is in the process of administrating the 

vaccine in its facilities.

As of 03/10/2021, the Bureau of Prisons has acquired 75,395 doses 

of the Covid-19 vaccine and is distributing it to staff and inmates. See

CDC Covid-19 Vaccine Tracker and BOP COVID-19 Vaccination 

Implementation. The Bureau of Prisons has already initiated the first 

dose of the vaccine in 321 of staff members and 327 inmates at Hazelton 

FCI. See CDC Covid-19 Vaccine Tracker and BOP COVID-19 

Vaccination Implementation. While the precise timing of each inmate’s 

vaccination will depend on many factors, the Bureau of Prisons is 

working swiftly to vaccinate inmates who consent to receive the vaccine. 

II. The Court should deny Hatmaker’s motion for 

compassionate release.

Hatmaker’s motion for a reduced sentence should be denied. A

district court has “no inherent authority . . . to modify an otherwise 

valid sentence.” United States v. Washington, 584 F.3d 693, 700 (6th 

Cir. 2009). Rather, a district court’s authority to modify a defendant’s 

sentence is “narrowly circumscribed.” United States v. Houston, 529 

F.3d 743, 753 n.2 (6th Cir. 2008). Absent a specific statutory exception, 

a district court “may not modify a term of imprisonment once it has 

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been imposed.” 18 U.S.C. § 3582(c). Those statutory exceptions are 

narrow. United States v. Ross, 245 F.3d 577, 586 (6th Cir. 2001).

Compassionate release under 18 U.S.C. § 3582(c)(1)(A) is equally 

narrow.

First, compassionate release requires exhaustion. 18 U.S.C. 

§ 3582(c)(1)(A); Alam, 960 F.3d at 832. This statutory exhaustion 

requirement is mandatory. Alam, 960 F.3d at 832–36.

Second, even if a defendant exhausts, he must show 

“extraordinary and compelling reasons” for release. 18 U.S.C. 

§ 3582(c)(1)(A). 

Third, even if a defendant is eligible for compassionate release, a

district court may not grant the motion unless the factors in 18 U.S.C. 

§ 3553(a) support release. 18 U.S.C. § 3582(c)(1)(A); United States v. 

Ruffin, 978 F.3d 1000, 1008–09 (6th Cir. 2020). As at sentencing, those 

factors require the district court to consider the defendant’s history and 

characteristics, the seriousness of the offense, the need to promote 

respect for the law and provide just punishment for the offense, general 

and specific deterrence, and the protection of the public. 18 U.S.C. 

§ 3553(a).

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A. Binding authority prohibits the Court from granting 

release, because Hatmaker has not satisfied the 

statutory exhaustion requirement.

The Court should dismiss Hatmaker’s motion because he has not 

satisfied the exhaustion requirement for compassionate release under 

18 U.S.C. § 3582(c)(1)(A). Until recently, only the Bureau of Prisons 

could move for compassionate release. The First Step Act of 2018 

amended the statute, permitting defendants to move for it too. First 

Step Act § 603(b), Pub. L. No. 115-319, 132 Stat. 5194, 5239 (Dec. 21, 

2018). 

But the provision permitting a defendant-initiated motion 

includes an exhaustion requirement. Id. A district court may not grant 

a defendant’s motion for compassionate release unless the defendant 

files it “after” the earlier of (1) the defendant “fully exhaust[ing] all 

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

bring a motion on the defendant’s behalf,” or (2) “the lapse of 30 days 

from the receipt of such a request by the warden of the defendant’s 

facility.” 18 U.S.C. § 3582(c)(1)(A); Alam, 960 F.3d at 832. This 

statutory exhaustion requirement is “a mandatory condition” that 

“must be enforced” when the government raises it. Id. at 832–36; accord 

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United States v. Raia, 954 F.3d 594, 595–97 (3d Cir. 2020). Hatmaker 

has not satisfied the exhaustion requirement because he filed his 

motion less than 30 days after he made a request to the warden under 

§ 3582(c)(1)(A). In fact, BOP records show that Hatmaker never made a 

request for compassionate release before he filed his motion, and 

instead only recently, on March 9, 2021, made a request for 

compassionate release. (See Exhibit C.). No decision has yet been made 

on that request.

B. Hatmaker has shown “extraordinary” 

and“compelling” reasons for compassionate release. 

Even if Hatmaker had exhausted, he is not eligible for release. 

Resolving the merits of a compassionate-release motion involves a 

“three-step inquiry”: a district court must (1) “find that extraordinary 

and compelling reasons warrant a sentence reduction,” (2) “ensure that 

such a reduction is consistent with applicable policy statements issued 

by the Sentencing Commission,” and (3) “consider all relevant 

sentencing factors listed in 18 U.S.C. § 3553(a).” Elias, ___ F.3d ___, No. 

20-3654, 2021 WL 50169, at *2 (6th Cir. Jan. 6, 2021); 18 U.S.C. 

§ 3582(c)(1)(A). In Elias, 2021 WL 50169, at *2, the Sixth Circuit held 

that USSG § 1B1.13 is not an “applicable” policy statement for

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defendant-initiated motions for compassionate release. The government 

disagrees with that holding and preserves for further review its 

argument that § 1B1.13 remains binding. But, given the Sixth Circuit’s 

holding in Elias, controlling circuit precedent now forecloses that 

argument before this Court.

The government agrees that Hatmaker’s circumstances qualify as 

“extraordinary and compelling reasons.” His medical records establish 

that he has Heart Disease (unstable angina and aortic stenosis) which 

the CDC has confirmed is a risk factor that places a person at increased 

risk of severe illness from Covid-19. See Exhibits A and B (filed under 

seal); CDC Risk Factors (as updated). Given the heightened risk that 

Covid-19 poses to someone with that medical condition, Hatmaker has

satisfied the initial eligibility criteria for release under § 3582(c)(1)(A). 

C. The factors in 18 U.S.C. § 3553(a) strongly weigh 

against compassionate release.

Even when an inmate has shown “extraordinary and compelling 

reasons,” he is still not entitled to compassionate release. Before 

ordering relief, the Court must consider the factors set forth in 18 

U.S.C. § 3553(a) and determine that release is appropriate. 18 U.S.C. 

§ 3582(c)(1)(A). A defendant’s failure to establish that the § 3553(a) 

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factors support relief is an independent basis for denying compassionate 

release. United States v. Ruffin, 978 F.3d 1000, 1008–09 (6th Cir. 2020); 

accord United States v. Austin, 825 F. App’x 324, 325–27 (6th Cir. 2020) 

(upholding a district court’s denial of compassionate release based on 

the § 3553(a) factors); United States v. Kincaid, 802 F. App’x 187, 188–

89 (6th Cir. 2020) (same). 

This Court’s “initial balancing of the § 3553(a) factors during [the 

defendant’s] sentencing” is presumed to “remain[] an accurate 

assessment as to whether those factors justify a sentence reduction”. 

United States v. Sherwood, 2021 WL ____, at * ____(6th Cir. Feb. 2, 

2021). The defendant must therefore “make a compelling case as to why 

the sentencing court’s § 3553(a) analysis would be different if conducted 

today.” Id. Here, even if the Court were to find that Hatmaker

established extraordinary and compelling reasons for his release, the 

§ 3553(a) factors should still disqualify him.

For starters, Hatmaker’s remaining sentence weighs heavily 

against release. The Sixth Circuit has repeatedly upheld the denial of 

compassionate release under § 3553(a) when a defendant has a long 

remaining sentence, including in a recent published decision. Ruffin, 

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978 F.3d at 1008; accord Kincaid, 802 F. App’x at 188–89; Austin, 825 

F. App’x at 326; see also United States v. Kincaid, 805 F. App’x 394, 

395–96 (6th Cir. 2020) (“[W]e don’t think [the defendant] raises a close 

question.”). This is because the original sentence already reflects the 

district court’s evaluation of “the need to provide just punishment, the 

need to reflect the seriousness of the offense, and the need to promote 

respect for the law” under § 3553(a). Kincaid, 802 F. App’x at 188; 

accord Ruffin, 978 F.3d at 1008. 

Considering his remaining sentence—another approximately 3

years—and the fact that he has never accepted responsibility for most of

the racketeering acts the Court held him accountable for, Hatmaker is

particularly unsuited for what would be a fairly sizable sentence 

reduction. 

The plain language of the compassionate-release statute makes 

the point even more directly: it requires that the defendant’s reasons for 

release “warrant such a reduction” in his sentence. 18 U.S.C. 

§ 3582(c)(1)(A)(i). That inquiry depends, at least in part, on the length 

of time remaining on the defendant’s sentence, requiring him to justify 

the magnitude of his requested sentence reduction. Id. So a defendant 

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with many years left on his sentence, like Hatmaker, must show that 

his reasons for release are so powerful that they “warrant” a “reduction” 

of that size. Id.

In terms of the seriousness of the offense, Hatmaker was 

convicted of being part of a criminal RICO enterprise, the Detroit 

Highwaymen outlaw motorcycle gang – an extremely dangerous group 

that was involved in murder, extortion, arson and drug trafficking, and 

was often in hostile territorial conflict with other outlaw motorcycle 

gangs. According to one interceptee of electronic surveillance: “I’ll tell 

you of all the motherfuckers in the club, that’s the last man I would 

ever want mad at me is fucking Ronnie Hatmaker.” He goes on to say: 

“You better do it because Ronnie will hunt you to the fucking four 

corners of the earth.” (R 1678. Government Supplemental Sentencing 

Memorandum p.3). 

The original 188 month sentence the Court imposed satisfied the 

need to promote respect for the law and provide just punishment for the 

offenses and protection of the public from further crimes and violence 

from this defendant. After all, the Highwaymen terrorized Southwest 

Detroit and the surrounding community for years. Hatmaker, as a 

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national leader in the organization, was very much part of that culture 

and, in fact, directed those activities. Moreover, although Hatmaker’s 

original sentencing guidelines called for a 240 month sentence, the 

Court imposed a below-guideline sentence of 188 months(later reduced 

to 170 months). To date, he has served only approximately 59.6% of the 

170 month sentence, and therefore reducing his sentence and releasing 

him now would seriously undermine several important goals served by 

the § 3553 sentencing factors.

In particular, this Court appropriately considered the need for its 

sentence to promote respect for the law, provide just punishment, deter 

criminal conduct, and protect the public when it sentenced Hatmaker. 

Granting the extraordinary relief requested here and reducing his 

sentence by such a significant amount would seriously undermine those 

sentencing goals. See, e.g., United States v. Knight, No. 15-20283, 2020 

WL 3055987, at *3 (E.D. Mich. June 9, 2020) (“Allowing [defendant] to 

be released after only serving about a third of his sentence would not 

promote respect for the law or proper deterrence, provide just 

punishment, and avoid unwarranted sentencing disparities.”); United 

States v. Dupree Rich, No. 17-CR-20032, ECF No. 56 (E.D. Mich. Sept. 

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9, 2020) (denying compassionate release, after government had 

conceded “extraordinary and compelling reason,” where defendant had a 

lengthy criminal history and bond violations, and had served less than 

half of his 100-month sentence for possession with intent to distribute 

cocaine).

Hatmaker’s record casts significant doubt on whether he would 

abide by the release conditions and social-distancing protocols that 

could diminish his risk of contracting Covid-19 if released from custody.

Although the average person might have a higher risk of contracting or 

developing complications from Covid-19 in prison than if released, an 

individual defendant’s risk varies widely. It depends on a long list of 

variables, including the precautions at his prison, the number of Covid19 cases there, the prison’s medical facilities, his access to medical care 

if released, and the threat from Covid-19 at his release location. A 

defendant’s risk of contracting Covid-19 also depends not just on his 

opportunities for social-distancing, but on his willingness to take 

advantage of those opportunities and engage in social-distancing for the 

pandemic’s duration. Hatmaker, however, is unlikely to abide by 

release restrictions and is thus more likely than most people to expose 

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himself and innocent people to Covid-19. Contrary to his suggestion 

that he would abide by all conditions of release, while in prison on 

4/25/2018, Hatmaker was disciplined for possession of a weapon that 

was attached to the underside of his bunk with a magnet. His in-prison 

conduct does not seem that much different than the outlaw biker 

lifestyle he enjoyed before his incarceration. (See Exhibit D.)

The § 3553(a) factors weigh against granting Hatmaker’s motion.

IV. Conclusion

Hatmaker’s motion should be denied.

Respectfully submitted,

SAIMA S. MOHSIN

Acting United States Attorney

s/ Eric M. Straus

Eric M. Straus P38266

Assistant United States Attorney

211 W. Fort Street, Suite 2001

Detroit, MI 48226

(313) 226-9648

Eric.Straus@usdoj.gov

Dated: March 16, 2021

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CERTIFICATE OF SERVICE

I hereby certify that on March 16, 2021, I electronically filed the 

foregoing document with the Clerk of the Court using the ECF system 

which will send a notice of such filing to all counsel of record. In 

accordance with the government’s protocol during the Covid-19 

pandemic, a copy of the foregoing will either be mailed to an attorney 

for the BOP for delivery to petitioner, or mailed (on the next allowed 

admittance to the government’s office to conduct outbound mailings) to 

the petitioner at the following:

Ronald Hatmaker

REG: 43499-039

Hazelton U.S. Penitentiary

Inmate mail/parcels

PO BOX 5000

Bruceton Mills, WV 26525

s/ Eric M. Straus

Eric M. Straus P38266

Assistant United States Attorney

211 W. Fort Street, Suite 2001

Detroit, MI 48226

(313) 226-9648

Eric.Straus@usdoj.gov

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