Order and Reasons — U.S. v. Ronald Taylor (E.D. La.)

Summary

An Order and Reasons filed April 17, 2026 as Document 57 in United States v. Ronald Taylor, Criminal Action No. 23-271, Section D (3), in the U.S. District Court for the Eastern District of Louisiana. The Court construes a letter received July 21, 2025 as a Motion for Modification of Sentence under 18 U.S.C. § 3582(c)(1)(A); the letter asks for a sentence reduction based on an Executive Order that Taylor says he "discovered as of May 5, 2025." The order recounts a sentence of 82 months' imprisonment imposed on October 1, 2024 for being a felon in possession of a firearm and ammunition. The Court finds no supporting Executive Order, no exhaustion of administrative remedies and no showing of "extraordinary and compelling reasons," and states that the Motion is DENIED.

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     Case 2:23-cr-00271-WBV-EJD             Document 57        Filed 04/17/26       Page 1 of 11




                          UNITED STATES DISTRICT COURT

                          EASTERN DISTRICT OF LOUISIANA

UNITED STATES OF AMERICA                                               CRIMINAL ACTION

VERSUS                                                                 NO. 23-271

RONALD TAYLOR                                                          SECTION D (3)

                                    ORDER and REASONS

         Before the Court is a letter from defendant, Ronald Taylor, that was received

by the Court on July 21, 2025.1 In the letter, Taylor requests a sentence reduction

based upon an Executive Order issued by President Donald J. Trump, which Taylor

“discovered as of May 5, 2025.”2 The Court construes the letter as a Motion for

Modification of Sentence pursuant to 18 U.S.C. § 3582(c)(1)(A).3 On July 24, 2025,

the Court issued an Order requiring the United States Attorney for the Eastern

District of Louisiana to file a response setting forth the Government’s position

regarding Taylor’s Motion.4 The Government timely filed a Response, asserting that

the Motion should be denied because there is no Executive Order that supports

Taylor’s request for a sentence reduction and because Taylor is not entitled to relief




1 R. Doc. 53.
2 Id. at p. 1.
3 Taylor does not appear to seek relief pursuant to 18 U.S.C. § 3582(c)(2), which allows the Court to

modify a term of imprisonment when a defendant “has been sentenced to a term of imprisonment
based on a sentencing range that has subsequently been lowered by the Sentencing Commission
pursuant to 28 U.S.C. § 994(o).” Taylor was sentenced on October 1, 2024 for being a felon in possession
of a firearm and ammunition, in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(8). R. Docs. 48 & 49.
The Sentencing Commission has not lowered the sentencing range for that crime since October 2024.
4 R. Doc. 54.
    Case 2:23-cr-00271-WBV-EJD           Document 57        Filed 04/17/26       Page 2 of 11




under § 3582(c)(1)(A).5 After careful consideration of the Motion, the Government’s

Opposition brief, and the applicable law, the Motion is DENIED.

    I.         FACTS AND PROCEDURAL HISTORY

         On December 8, 2023, Ronald Taylor was charged in a one-count indictment

with being a felon in possession of a firearm and ammunition, in violation of 18 U.S.C.

§§ 922(g)(1) and 924(a)(8).6 Taylor entered a guilty plea to the one-count indictment

on May 16, 2024.7         On July 29, 2024, the Court notified Taylor that it was

contemplating an upward variance based upon the sentencing factors set forth in 18

U.S.C. § 3553(a).8       On October 1, 2024, Taylor was sentenced to 82 months’

imprisonment and 3 years of supervised release.9 While Taylor’s sentencing guideline

range was 37 to 46 months, the Court determined that an upward variance was

warranted for the reasons stated on the record.10 Specifically, the Court found an

upward variance was warranted based upon Taylor’s criminal history, which reflects

a lack of respect for the law, and to reflect the seriousness of the crime and afford

adequate deterrence to criminal conduct. Taylor is serving his sentence at United

States Penitentiary Federal Correctional Complex in Coleman, Florida, and his

expected release date is August 19, 2029.11

         Taylor filed the instant Motion on July 21, 2025, asserting that, “I discovered

as of May 5, 2025 President ‘Trump’ issued an Executive Order ‘retroactive [sic] in


5 R. Doc. 55.
6 R. Doc. 1.
7 R. Doc. 28.
8 R. Doc. 36.
9 R. Doc. 49.
10 R. Doc. 48.
11 See https://perma.cc/FX5T-BYZT (Inmate Locator, Federal Bureau of Prisons).
     Case 2:23-cr-00271-WBV-EJD      Document 57      Filed 04/17/26   Page 3 of 11




regards of the 922(g)(1) possession of a firearm by a convicted felon charge,” and that,

“[t]he said order applies to me.”12 Taylor further asserts that pursuant to this order,

“anyone who was convicted of being a felon in possession of a firearm without any

predicate offenses is entitle [sic] to relief and sentence reduction,” and Taylor asks

this Court “to reduce ‘Ronald Taylor’ down to a guideline sentence or the lowest

permissible sentence possible.”13

         At the Court’s request,14 the Government filed a Response to Taylor’s Motion

to Reduce Sentence.15     The Government asserts that after reviewing the list of

Executive Orders on the White House webpage, it found only two orders issued on

May 5, 2025, neither of which pertains to 18 U.S.C. § 922(g) or to sentencing

reductions more generally.16 The Government claims that it also reviewed Executive

Orders issued around that date and found nothing on point.17 The Government

further asserts that, to the extent Taylor’s Motion is construed as a motion to reduce

his sentence under 18 U.S.C. § 3582, the Motion should be denied because Taylor has

not exhausted his administrative remedies, nor has Taylor shown that “extraordinary

and compelling reasons warrant such a reduction,” both of which are required by §

3582(c)(1)(A)(i).18




12 R. Doc. 53 at p. 1.
13 Id.
14 R. Doc. 54.
15 R. Doc. 55.
16 Id. at p. 1.
17 Id.
18 Id. at p. 2.
    Case 2:23-cr-00271-WBV-EJD           Document 57        Filed 04/17/26     Page 4 of 11




          While the Court gave Taylor until September 12, 2025 to file a Reply

memorandum in further support of his Motion,19 Taylor has not filed a Reply brief.

    II.      LAW AND ANALYSIS

          Before reaching the merits of Taylor’s request, the Court notes that Taylor is

proceeding pro se and, as instructed by the Fifth Circuit, this Court gives pro se briefs

a liberal construction.20 Even under a liberal construction, however, the Court finds

that Taylor has failed to show that a sentence reduction is appropriate in this case.

             A. Taylor Failed to Identify an Executive Order That Supports His
                Request for a Sentence Reduction.

          While Taylor seems to request a sentence reduction based upon an Executive

Order that he “discovered as of May 5, 2025,” the Court is unable to locate an

Executive Order issued around that time that supports Taylor’s request. President

Trump signed 142 Executive Orders in the first 100 days of his second term, or by

April 30, 2025.21 After conducting an exhaustive search, the Court has not found any

Executive Orders issued during that time that would support Taylor’s request for a

sentence reduction. The Government correctly points out that two Executive Orders

were signed on May 5, 2025, entitled “Improving the Safety and Security of Biological

Research” and “Regulatory Relief to Promote Domestic Production of Critical

Medicines.”22 Neither of these orders address sentence reductions. While there is a




19 R. Doc. 54.
20 Brown v. Sudduth, 675 F.3d 472, 477 (5th Cir. 2012) (citing Mayfield v. Tex. Dep’t of Criminal

Justice, 529 F.3d 599, 604 (5th Cir. 2008)).
21 See https://perma.cc/JXP3-L8KX (“Trump sets executive order record in his first 100 days” – CBS

News).
22 See https://perma.cc/7QQ6-MZXD (List of Executive Orders from the White House’s website).
     Case 2:23-cr-00271-WBV-EJD        Document 57      Filed 04/17/26    Page 5 of 11




May 9, 2025 Executive Order entitled, “Fighting Overcriminalization in Federal

Regulations,” it does not concern sentence reductions or the felon in possession

statute, 18 U.S.C. § 922(g)(1).23 As such, the Court finds that Taylor has failed to

demonstrate that a sentence reduction is appropriate based upon an Executive Order

issued at or around May 5, 2025.

          B. Taylor Failed to Exhaust His Administrative                        Remedies
             Pursuant to 18 U.S.C. § 3582(c)(1)(A).

       Generally, federal courts “may not modify a term of imprisonment once it has

been imposed.”24 As explained by the Fifth Circuit, “[p]rior to the passage of the First

Step Act of 2018, Pub. L. No. 115-391, 132 Stat. 5194 (2018), federal courts lacked the

power to adjudicate motions for compassionate release.”25 Now, however, a court

“may reduce the term of imprisonment” upon the request of a defendant under 18

U.S.C. § 3582(c).26 Section 3582(c)(1) provides, in pertinent part, that:

              (A) the court, upon motion of the Director of the Bureau of
              Prisons, or upon motion of the defendant 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, may reduce the term of
              imprisonment . . . after considering the factors set forth in
              section 3553(a) to the extent that they are applicable, if it
              finds that —
                      (i) extraordinary and compelling reasons warrant
                      such a reduction; or
                      (ii) the defendant is at least 70 years of age, has
                      served at least 30 years in prison, pursuant to a

23  See https://perma.cc/774B-5H84 (Executive Order “Fighting Overcriminalization in Federal
Regulations”).
24 18 U.S.C. § 3582(c).
25 United States v. Franco, 973 F.3d 465, 467 (5th Cir. 2020).
26 18 U.S.C. § 3582(c)(1)(A) & (2).
    Case 2:23-cr-00271-WBV-EJD             Document 57        Filed 04/17/26      Page 6 of 11




                        sentence imposed under section 3559(c), for the
                        offense or offenses for which the defendant is
                        currently imprisoned, and a determination has been
                        made by the Director of the Bureau of Prisons that
                        the defendant is not a danger to the safety of any
                        other person or the community, as provided under
                        section 3142(g);

                        and that such a reduction is consistent with
                        applicable policy statements issued by the
                        Sentencing Commission; . . . .27

The Fifth Circuit has made clear that the exhaustion requirement in § 3582(c)(1)(A)

is mandatory and that a defendant must first file a request with the Bureau of Prisons

before petitioning a court for compassionate release.28

        Here, Taylor has failed to provide any information indicating that he

exhausted his administrative remedies prior to filing the instant Motion. Taylor has

not produced any documentation from the United States Penitentiary Federal

Correctional Complex in Coleman, Florida showing that he submitted a request to

the Warden for a sentence reduction. As such, there is no evidence before the Court

that Taylor has satisfied the exhaustion requirement for relief under § 3582(c)(1)(A).

The Court finds that Taylor has failed to demonstrate that he has exhausted his

administrative remedies, as required to obtain relief under 18 U.S.C. § 3582(c)(1)(A).




27 18 U.S.C. § 3582(c)(1)(A).
28 Franco, 973 F.3d at 468 (citing United States v. Alam, 960 F.3d 831, 832 (6th Cir. 2020); United

States v. Raia, 954 F.3d 594, 597 (3d Cir. 2020); United States v. Springer, 820 Fed.Appx. 788, 790–92
(10th Cir. 2020)).
    Case 2:23-cr-00271-WBV-EJD            Document 57   Filed 04/17/26   Page 7 of 11




             C. Taylor Failed to Show Extraordinary and Compelling Reasons
                Warrant a Sentence Reduction.

        In addition to finding that Taylor failed to exhaust his administrative

remedies, the Court also finds that Taylor has failed to present any “extraordinary

and compelling reasons” that would warrant a sentence reduction under 18 U.S.C. §

3582(c)(1)(A)(i).29      Under § 3582(c)(1)(A), the Court may only reduce a term of

imprisonment when it finds that: (1) “extraordinary and compelling reasons warrant

such a reduction;” or (2) the defendant is at least 70 years old, has served at least 30

years in prison for the offense or offenses for which he is currently imprisoned, and a

determination has been made by the Director of the Bureau of Prisons that the

defendant is not a danger to the safety of any other person or the community.30

Because Taylor is under 70 years old,31 he must show that “extraordinary and

compelling reasons” warrant a sentence reduction. Additionally, the Court must find

that, “such a reduction is consistent with applicable policy statements issued by the

Sentencing Commission.”32

        The United States Sentencing Guidelines identify six circumstances under

which “extraordinary and compelling reasons” exist to warrant a sentence reduction:

(1) a “terminal illness” or a condition that “substantially diminishes the ability of the

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

from which he or she is not expected to recover;” (2) the age of the defendant,




29 18 U.S.C. § 3582(c)(1)(A)(i).
30 18 U.S.C. § 3582(c)(1)(A)(i) & (ii).
31 R. Doc. 34 at p. 4.
32 18 U.S.C. § 3582(c)(1)(A).
   Case 2:23-cr-00271-WBV-EJD        Document 57      Filed 04/17/26   Page 8 of 11




specifically, the defendant must be at least 65 years old, experiencing a serious

deterioration in physical or mental health because of the aging process, and he or she

must have served at least 10 years or 75% of his or her term of imprisonment,

whichever is less; (3) family circumstances, including the death or incapacitation of

the caregiver of the defendant’s minor child or the defendant’s child who is 18 years

of age or older and incapable of self-care because of a mental or physical disability or

a mental condition, the incapacitation of the defendant’s spouse or registered partner

when the defendant would be the only available caregiver for the spouse or registered

partner, the incapacitation of the defendant’s parent when the defendant would be

the only available caregiver for the parent, or the defendant establishes that similar

circumstances exist involving any other immediate family member or an individual

whose relationship with the defendant is similar in kind to that of an immediate

family member and the defendant would be the only available caregiver for such

family member or individual; (4) the defendant, while in custody serving the term of

imprisonment sought to be reduced, was a victim of: (a) sexual abuse involving a

“sexual act,” as defined in 18 U.S.C. § 2246(2); or (b) physical abuse resulting in

“serious bodily injury,” as defined in the Commentary to § 1B1.1 of the United States

Sentencing Guidelines; (5) any other circumstance or combination of circumstances

that, when considered by themselves or together with any of the four prior examples,

are similar in gravity to those described therein; and (6) if the defendant received an

unusually long sentence and has served at least 10 years of the term of imprisonment

and there was a change in the law (other than an amendment to the Guidelines
    Case 2:23-cr-00271-WBV-EJD         Document 57   Filed 04/17/26   Page 9 of 11




Manual that has not been made retroactive), but only where such change would

produce a gross disparity between the sentence being served and the sentence likely

to be imposed at the time the motion is filed, and after full consideration of the

defendant’s individualized circumstances.33

        Here, Taylor’s Motion does not mention his age, family circumstances, a

terminal illness, abuse, an unusually long sentence, or any other example of

“extraordinary and compelling reasons” set forth in United States Sentencing

Guideline § 1B1.13 that would support a sentence reduction under 18 U.S.C. §

3582(c)(1)(A)(i). Instead, Taylor asserts that a sentence reduction is appropriate

under an Executive Order purportedly issued at some time before May 5, 2025. As

such, the Court finds that Taylor has failed to show that extraordinary and

compelling reasons warrant a sentence reduction in this case at this time.

             D. The Armed Career Criminal Act Does Not Support a Sentence
                Reduction.

        Taylor asserts in his Motion that, based upon an Executive Order issued by

President Trump, “anyone who was convicted of being a felon in possession of a

firearm without any predicate offenses is entitle [sic] to relief and sentence

reduction.”34       Liberally construing Taylor’s Motion, it appears that he may be

asserting that he erroneously received a sentencing enhancement under 18 U.S.C. §

924(e)(1), the Armed Career Criminal Act (“ACCA”), because there were no predicate

offenses to support the enhancement. The Court rejects that argument as meritless.



33 See, U.S.S.G. § 1B1.13.
34 R. Doc. 53 at p. 1.
   Case 2:23-cr-00271-WBV-EJD               Document 57        Filed 04/17/26       Page 10 of 11




On December 8, 2023, Taylor was charged in a one-count indictment with being a

felon in possession of a firearm and ammunition, in violation of 18 U.S.C. §§ 922(g)(1)

and 924(a)(8).35         At the time Taylor was indicted, § 924(a)(8) provided that the

statutory maximum sentence for a violation of § 922(g)(1) was 15 years’

imprisonment.36 The Court sentenced Taylor to 82 months’ imprisonment pursuant

to §§ 922(g)(1) and 924(a)(8), which was an upward variance from the advisory

guideline imprisonment range.37 Under the ACCA, which is set forth in 18 U.S.C. §

924(e)(1), “a defendant convicted under § 922(g)(1) is subject to an enhanced

punishment if she has three or more prior convictions for violent felonies or serious

drug offenses committed on occasions different from one another.”38 Because Taylor

was sentenced pursuant to 18 U.S.C. § 924(a)(8), and did not receive a sentence

enhancement under § 924(e)(1), the Court finds that Taylor is not entitled to a

sentence reduction based upon the erroneous application of the Armed Career

Criminal Act.

    III.        CONCLUSION

           For the foregoing reasons, IT IS HEREBY ORDERED that Ronald Taylor’s




35 R. Doc. 1.
36 18 U.S.C. § 924(a). See United States v. Butler, 122 F.4th 584, 588, n.3 (5th Cir. 2024) (noting that,
“In June 2022, . . . Congress passed the Bipartisan Safer Communities Act, which increased the
maximum penalty for a violation of § 922(g)(1) from 10 years to 15 years’ imprisonment and moved the
statutory maximum provision to § 924(a)(8). See Bipartisan Safer Communities Act, Pub. L. No. 117-
159, § 12004(c), 136 Stat. 1313, 1329 (2022); see also 18 U.S.C. § 924(a)(8).”).
37 R. Doc. 49.
38 Butler, 122 F.4th at 588 (quoting 18 U.S.C. § 924(e)(1)) (citation modified).
   Case 2:23-cr-00271-WBV-EJD       Document 57   Filed 04/17/26   Page 11 of 11




Motion for Modification of Sentence pursuant to 18 U.S.C. § 3582(c)(1)(A)39 is

DENIED.

        New Orleans, Louisiana, April 16, 2026.



                                           ______________________________________
                                           WENDY B. VITTER
                                           UNITED STATES DISTRICT JUDGE




39 R. Doc. 53.


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