A federal judge concluded earlier this month that a man’s eight years allegedly spent in solitary confinement did not justify granting his request for a sentence reduction.

However, U.S. District Court Senior Judge William J. Martínez signaled his willingness to re-evaluate Randy Platt’s request if Platt details why his experience in prolonged isolation amounts to the type of “extraordinary and compelling circumstances” that can trigger a sentence reduction.

“The Court does not doubt that extended periods of solitary confinement may constitute extraordinary and compelling circumstances in certain situations,” Martínez wrote in a March 4 order. “Platt, however, does not supply sufficient facts or develop any argument as to why his personal circumstances, in combination with his prolonged solitary confinement, constitute extraordinary and compelling circumstances.”

Martínez sentenced Platt to 12.5 years in prison in 2022 for cutting a corrections officer’s arm with a razor blade. Platt remains at the U.S. Penitentiary, Administrative Maximum Facility in Florence.

Last June, Platt wrote to Martínez seeking compassionate release or a reduced sentence, in part based on changes to federal sentencing guidelines.

He added that he “has been held in solitary confinement for the past 8 years with no offer of transfer to a general population yard,” wrote Platt. “This in itself presents an ‘extraordinary and compelling reason’ for the fact that the physical, psychological, and emotional damage of long-term solitary confinement can never be reversed.”

Responding to Platt’s request, the government did not address Platt’s allegation of extended solitary confinement. Instead, it argued his history should weigh against any reduction to his punishment.

“Defendant Platt has an atrocious criminal record that stretches back more than 20 years and across Utah, Oklahoma, and Colorado,” wrote Assistant U.S. Attorney JD Rowell. “His disciplinary record while incarcerated is similarly replete with evidence of his inability to conform his conduct to rules while incarcerated.”

Rowell provided a chart with Platt’s numerous infractions in prison. However, the last entry was from August 2019, more than two years before Martínez sentenced Platt for his assault on the corrections officer.

Martínez, in his order, wrote that Platt was not eligible for a sentence reduction or compassionate release. He noted that he sentenced Platt to a lesser term of incarceration than the guidelines suggested.

Turning to Platt’s allegation of prolonged isolation, Martínez wrote that he “would have benefited from the Government weighing in on this solitary confinement issue, and is perplexed by the fact that it was ignored.”

“The Court appreciates that those conditions have likely been detrimental to his rehabilitation and mental and physical health,” Martínez continued. He quoted from an opinion by Senior Judge Carlos F. Lucero of the U.S. Court of Appeals for the 10th Circuit, who wrote in 2018 that he could not consider “such prolonged, unjustified confinement as anything other than extreme and atypical.”

“Still, Platt cites to no authority, and the Court is aware of none, providing that extended periods of solitary confinement alone necessarily constitutes extraordinary and compelling circumstances under the compassionate release statute,” wrote Martínez. “The Court has instead located caselaw suggesting that this issue is fact-dependent.”

Martínez cautioned that Platt’s “long and violent criminal history” would make it difficult for him to entertain a sentence reduction in the future. Still, he invited Platt to renew his motion after June, should Platt’s solitary confinement continue, with a detailed argument for why his particular circumstances should trigger relief.

The case is United States v. Platt.