What happened
The Eighth Circuit affirmed orders denying compassionate-release relief to Isaac Loggins Jr. and Barton Crandall, holding that nonretroactive changes to federal firearm-sentencing law cannot be used to make their older sentences eligible for reduction.
The ruling applies the Supreme Court's 2026 decision in Rutherford and preserves the Eighth Circuit's earlier approach in Crandall, rejecting the argument that a 2023 Sentencing Commission policy statement displaced circuit precedent on unusually long sentences.
The appeals turned on the First Step Act's reduction of mandatory penalties for repeated violations of 18 U.S.C. § 924(c). Loggins and Crandall were sentenced before those changes, and the statute made the amendments applicable only to defendants who had not yet been sentenced.
Both men sought compassionate release under 18 U.S.C. § 3582(c)(1)(A), arguing that the Sentencing Commission's amended policy statement allowed courts to consider unusually long sentences where a legal change would create a gross disparity between the sentence being served and the likely sentence today.
The Eighth Circuit said Rutherford foreclosed that position. Consistent with the Supreme Court's decision, the panel held that the First Step Act's nonretroactive Section 924(c) changes, like other nonretroactive legal changes, "cannot, whether offered alone or in combination with other insufficient factual considerations, constitute “extraordinary and compelling” reasons" for a sentence reduction.
The significance is practical for federal prisoners seeking sentence cuts after nonretroactive statutory amendments: in the Eighth Circuit, and under Rutherford's reading of the compassionate-release statute, the disparity created by Congress's choice not to make a sentencing change retroactive is not enough to open the door to relief.
The panel affirmed the district court orders denying both defendants' motions.