What happened
The U.S. Supreme Court ruled that prisoners serving long sentences under the former Section 924(c) firearm-stacking regime cannot rely on Congress' later, nonretroactive reduction of those penalties to qualify for compassionate release, holding that the sentencing disparity does not clear the statute's threshold requirement. Justice Amy Coney Barrett wrote for a six-justice majority that the disparity could not serve as an extraordinary and compelling reason for a sentence reduction: "We hold that it cannot."
The decision affirms the Third Circuit and resolves a split over whether courts may treat the First Step Act's nonretroactive changes to mandatory gun penalties as a gateway to compassionate release. The ruling limits the practical reach of the Sentencing Commission's 2023 policy statement recognizing an unusually long sentence and certain changes in law as possible grounds for relief.
The consolidated cases involved Daniel Rutherford and Johnnie Carter, who received lengthy mandatory minimums under the prior Section 924(c) stacking scheme. Rutherford's firearm counts produced a 32-year minimum and a total sentence of more than 42 years, while Carter received a 70-year sentence, 57 years of it tied to stacked Section 924(c) convictions. Congress later eliminated the 25-year stacking requirement for first-time offenders, but only for defendants who had not yet been sentenced.
The majority said compassionate release remains a narrow exception to the general rule that a prison sentence, once imposed, usually cannot be modified. In its view, nonretroactive sentencing amendments are not extraordinary because they are common features of criminal law, and they are not compelling because Congress deliberately chose not to extend the new penalties to people already sentenced.
The Court also rejected reliance on the Sentencing Commission's updated policy statement. The majority said the Commission may identify extraordinary and compelling reasons, but its policy statements must remain consistent with the governing statute; to the extent the 2023 statement allowed the Section 924(c) disparity to make a prisoner eligible for compassionate release, the Court said it was invalid.
Justice Sonia Sotomayor dissented, joined by Justices Elena Kagan and Ketanji Brown Jackson. The dissent said courts should be allowed to consider sentencing disparities as part of individualized compassionate-release analysis and faulted the majority for imposing categorical limits that, in the dissent's view, neither Congress nor the Commission adopted.
The immediate consequence is that defendants sentenced before the First Step Act cannot use the gap between their old stacked Section 924(c) sentences and today's lower mandatory minimums to establish compassionate-release eligibility. The ruling still leaves room, once a prisoner independently establishes extraordinary and compelling reasons, for courts to consider sentencing disparities when weighing the Section 3553(a) factors.