The case centers on Joe Fernandez, who received a mandatory life sentence and whose district judge, after granting a compassionate release motion, cited concerns about the credibility of cooperating witnesses, the disparity between Fernandez's sentence and those of co-conspirators, and the fact that the getaway driver received only two years in prison. The government argues that those concerns amount to a recycled, non-cognizable challenge to the validity of the criminal judgment — the province of Section 2255, not Section 3582.
Benjamin Gruenstein, arguing for Fernandez, told the Court that Congress chose deliberately broad language when it established the extraordinary and compelling reasons standard and delegated to the Sentencing Commission the task of giving that standard content. He argued that nothing in the statute or its legislative history links the compassionate release inquiry to the habeas scheme, and that allowing courts to consider sentencing errors or unfairness in rare cases would not frustrate the procedural limitations of Section 2255.
Deputy Solicitor General Eric J. Feigin countered that Section 3582(c)(1)(A)(i) is a narrow exception to sentencing finality that presumes a valid sentence and is meant for exceptional personal circumstances — not an open-ended mechanism to relitigate claims that could have been, or were, raised under Section 2255. He warned that a ruling for Fernandez would effectively eradicate the substantive, procedural, and temporal limits on Section 2255 claims and on collateral attacks on criminal judgments, noting that any of the roughly 5,000 prisoners who file 2255 motions in a year could simply recycle those claims under 3582.
Several justices pressed hard on workability from both directions. Chief Justice Roberts questioned whether the category of eligible motions would truly remain rare, suggesting that any lawyer with a non-frivolous claim of error would file one. Justice Alito raised the prospect of district judges using the statute to effectively override mandatory minimums they dislike. Justice Kavanaugh noted that neither Congress nor the Sentencing Commission has authorized, envisioned, or articulated anything close to legal error as a basis for this kind of relief, and suggested that absence should carry significant weight.
Justices Jackson and Sotomayor pushed back on the government's position. Justice Jackson questioned whether the government's rule — barring anything that could be raised in habeas — was workable at all, given that the line between habeas-cognizable claims and other concerns is not always clear. She also noted that the statute contains no text limiting relief to personal circumstances. Justice Sotomayor observed that the two published opinions from the era when the Bureau of Prisons controlled the process were not limited to personal circumstances, and she questioned the government's characterization of the Diaco case.
A recurring fault line involved freestanding actual innocence claims. Justice Kavanaugh asked where a prisoner with newly discovered evidence of innocence, unpaired with a constitutional claim, could go if not to compassionate release — and Feigin acknowledged the answer was essentially the clemency process. Justice Barrett pressed whether the Court would need to resolve whether a freestanding actual innocence claim is cognizable under Section 2255 before it could apply the government's proposed rule, a question the Court has never squarely addressed. Feigin responded that he would frame the government's rule more broadly as excluding anything that attacks the validity of a conviction or sentence, rather than tying it specifically to what is cognizable under 2255.
The case is Fernandez v. United States, No. 24-556.