WASHINGTON, D.C. — The Supreme Court ruled in two cases, Fernandez v. United States and Rutherford v. United States, that challenges to the validity of a conviction and nonretroactive changes to federal sentencing laws cannot serve as grounds for compassionate release. The decisions clarify that compassionate release is intended to address extraordinary personal circumstances, not legal or sentencing disputes.

In Fernandez v. United States, the Court held that a defendant’s claim that his conviction was invalid—based on assertions of being framed and doubts about a key witness’s credibility—does not constitute an “extraordinary and compelling reason” for sentence reduction. The Court concluded that allowing such arguments in compassionate release motions would circumvent the procedural limits of habeas corpus relief under 28 U.S.C. § 2255, which imposes a one-year statute of limitations and restricts relitigation of previously rejected claims.

Justice Amy Coney Barrett, writing for the majority, stated, “To be clear: Fernandez is challenging the validity of his conviction, even though he is not asking to have it vacated or set aside.” She added that Fernandez’s argument “highlighted the mismatch between the alleged error and the remedy sought.” Barrett emphasized that the compassionate release statute is meant to grant mercy based on personal circumstances such as age or illness, not to correct perceived legal wrongs.

In Rutherford v. United States, the Court ruled that nonretroactive reductions in mandatory minimum penalties for firearm offenses under 18 U.S.C. § 924(c) cannot justify compassionate release. Congress had amended the law in the First Step Act of 2018 to lower penalties for certain repeat offenders but chose not to apply the changes retroactively. Barrett explained that compassionate release requires a reason that is, at minimum, “especially unusual and convincing,” and that Congress’s decision to make a penalty change nonretroactive is neither unusual nor convincing.

The Court also invalidated a U.S. Sentencing Commission guideline that had permitted compassionate release based on nonretroactive statutory changes, finding it conflicted with the statutory framework. Barrett wrote, “A speaker’s choice to rule out one item does not always mean that the rest of the universe is on the table.” She further noted that the Bureau of Prisons is not equipped to evaluate legal challenges to convictions.

Justice Sonia Sotomayor, joined by Justice Elena Kagan, concurred in the Fernandez result on narrower grounds, while Justice Ketanji Brown Jackson dissented in that case. In Rutherford, Sotomayor, Kagan, and Jackson dissented.