Further, “a defendant's mere dissatisfaction with his course of medical treatment does not create such extraordinary and compelling reasons as to justify a sentence reduction.” United States v. Heck, No. 3:17-cr-224-MMH-MCR, 2021 WL 1172938, at *5 (M.D. Fla. Mar. 29, 2021) (internal quotation marks, alterations, and citation omitted). To the extent Defendant seeks compassionate release because administrators at Fort Dix FCI mismanaged the COVID-19 pandemic, that is not a circumstance that falls within the definition of “extraordinary and compelling reasons” under the policy statement.
That will often be a powerful consideration in deciding whether compassionate release is warranted. See, e.g., United States v. Heck, No. 3:17-cr-224-MMH-MCR, 2021 WL 1172938, at *5-7 (M.D. Fla. Mar. 29, 2021) (finding that defendant's conditions did not rise to the level of extraordinary and compelling circumstances where his diabetes and blood pressure were well-controlled). However, there remains the issue of Hagan's severe obesity, which compounds his risk of severe illness from Covid-19, and which neither he nor the BOP can do much about in the short term.