United States of America v. Tyler Z. Cobb

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted October 15, 2024*
Decided October 16, 2024
Before
MICHAEL Y. SCUDDER, Circuit Judge
JOHN Z. LEE, Circuit Judge
NANCY L. MALDONADO, Circuit Judge
No. 24-2119
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
TYLER Z. COBB,
Defendant-Appellant.
Appeal from the United States District
Court for the Southern District of
Indiana, Indianapolis Division.
No. 1:20-cr-00192-JRS-MG-1
James R. Sweeney II,
Judge.
O R D E R
Tyler Cobb, a federal prisoner serving a 125-month sentence for possession of
child pornography, appeals the denial of his motion for compassionate release. Because
* We have agreed to decide the case without oral argument because the briefs and
record adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 24-2119 Page 2
his arguments on appeal improperly challenge the validity of his conviction and
sentence and do not address the district court’s reasons for denying compassionate
release, we affirm.
Cobb pleaded guilty in 2021 to one count of possessing child pornography.
18 U.S.C. § 2252(a)(4)(B). Based on an offense level of 38 and a criminal history category
of I, Cobb’s guidelines range was 235 to 293 months, capped by a statutory maximum of
240 months. See id. § 2252(b)(2); U.S.S.G. § 2G2.2. Considering Cobb’s young age as well
as his mental and physical impairments, the court imposed a below-guidelines sentence
of 125 months’ imprisonment and 360 months’ supervised release.
After serving 27 months in prison, Cobb filed a motion for compassionate release
in May 2024. 18 U.S.C. § 3582(c)(1)(A)(i). He argued that his serious and permanent
medical conditions—encephalopathy, periventricular leukomalacia, chronic lung
disease, scoliosis, cerebral palsy, epilepsy, cognitive dysfunction, borderline IQ, anxiety
disorder, and panic attacks—and the Bureau of Prisons’ inability to treat them were
extraordinary and compelling reasons justifying early release. See U.S.S.G.
§ 1B1.13(b)(1)(A), (B). Cobb also argued that the illegality of his conviction and sentence
and his rehabilitative efforts in prison supported his release. See U.S.S.G. § 1B1.13(b)(5).
The district court denied the motion. The court reasoned that Cobb produced no
evidence that his medical conditions are terminal. Moreover, it determined that the
Bureau is capable of treating Cobb’s medical needs, and Cobb did not present evidence
that his ability to provide self-care in prison is diminished. The court also noted that the
challenges to the underlying conviction and sentence were not proper grounds for
compassionate release. The court therefore concluded that Cobb had not met his burden
of showing that extraordinary and compelling reasons warranted a reduced sentence.
Even assuming Cobb had presented an extraordinary and compelling reason for
release, the court explained that it still would deny relief because the sentencing factors
in 18 U.S.C. § 3553(a) weighed against it. Specifically, the court noted the seriousness of
Cobb’s crime, which involved children, the below-guidelines sentence that had already
accounted for Cobb’s medical conditions, and the substantial time remaining on his
sentence. The court determined these facts outweighed any rehabilitative efforts Cobb
had made while in prison. Accordingly, releasing Cobb early would not reflect the
seriousness of the offense, promote respect for the law, or provide adequate deterrence.

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No. 24-2119 Page 3
On appeal, Cobb does not engage with the district court’s reasoning. Rather, he
reiterates his challenges to the validity of his conviction and sentence. For example, he
argues that the prosecutor withheld exculpatory evidence and fabricated stories about
Cobb that influenced the court’s sentencing decision. But as the district court correctly
concluded, a compassionate release motion is not the proper vehicle to challenge a
conviction or sentence. See United States v. Von Vader, 58 F.4th 369, 371 (7th Cir. 2023).
Because Cobb’s brief does not address the district court’s conclusions that he did not
otherwise establish an extraordinary or compelling reason for release or that the
§ 3553(a) factors weighed against a sentence reduction, any argument along those lines
is waived. See Bradley v. Village of University Park, 59 F.4th 887, 897 (7th Cir. 2023).
Regardless, the district court needed to identify “just one good reason” for denying the
motion. United States v. Rucker, 27 F.4th 560, 563 (7th Cir. 2022). Here, the court provided
more than one good reason: Cobb’s medical conditions did not qualify as extraordinary
and compelling reasons for early release, and the seriousness of the crime and the
substantial time remaining on Cobb’s sentence weighed against release.
AFFIRMED

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