On March 26, 2025, Judge Jed S. Rakoff of the Southern District of New York denied Cesar Altieri Sayoc’s latest motion for compassionate release. Sayoc, currently serving a 20-year sentence for mailing pipe bombs to political figures, arguing that his health issues, conditions of confinement, and rehabilitation efforts amounted to extraordinary and compelling reasons warranting early release.
Sayoc had previously filed similar motions, which the court denied. In the latest motion, he cited his age (62), obesity, sleep apnea, a past gallbladder condition, and a previously detected kidney growth. However, the court found that his medical needs were being addressed by the Bureau of Prisons (BOP), noting he received a CPAP machine in May 2024 and that a physician had concluded in 2022 that no follow-up was needed for the kidney issue. These facts, the court held, did not meet the standard for extraordinary and compelling medical circumstances.
Sayoc also highlighted the hardships he experienced during the COVID-19 pandemic, the poor conditions at his facility, and his separation from family in Florida. Judge Rakoff acknowledged these concerns but emphasized that such generalized complaints about prison life and distance from family are not uncommon and do not meet the threshold required for sentence reduction. Although the BOP had since transferred Sayoc to a Florida facility, the court reiterated that placement decisions lie solely with the BOP.
In addition, Sayoc claimed his post-conviction rehabilitation supported early release. While the court commended his participation in rehabilitative programming, it firmly stated that rehabilitation alone does not qualify as an extraordinary and compelling reason under federal law.
Even assuming Sayoc had met the statutory standard, the court noted that the sentencing factors still weighed heavily against release. Judge Rakoff recalled that the original 20-year sentence reflected the severity of Sayoc’s crimes, which the court described as “horrendous.” Sayoc had not yet served even the portion of the sentence he originally requested (10 years and one month), and the court saw no reason to revisit its prior determination that the sentence imposed was appropriate.
Accordingly, the motion was denied.
Source: United States v. Sayoc, 2025 U.S. Dist. LEXIS 55967 (S.D.N.Y. Mar. 26, 2025).