Fernandez v. United States
No. 24-556 · Decided May 28, 2026 · affirmed
Does 18 U.S.C. §3582(c)(1)(A)(i) allow a district court to reduce a prisoner's sentence based on "extraordinary and compelling reasons" that challenge the validity of the underlying conviction? A prisoner who collaterally attacks the validity of his conviction must proceed through 28 U.S.C. §2255, as the supposed invalidity of a conviction is not among the "extraordinary and compelling reasons" that justify compassionate release under 18 U.S.C. §3582.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR · Argued November 12, 2025
Parties — Petitioner: FERNANDEZ · Respondent: UNITED STATES
Vote & lineup8–1 on the judgment. Barrett delivered the opinion of the Court, joined by Roberts, Thomas, Alito, Gorsuch, Kavanaugh (6). Dissent(s): Jackson. Concurrence(s): Sotomayor (joined by Kagan).
Who prevailed — The respondent prevailed, as the Court affirmed the Second Circuit's decision reversing the grant of compassionate release to the petitioner.
The question

Does 18 U.S.C. §3582(c)(1)(A)(i) allow a district court to reduce a prisoner's sentence based on "extraordinary and compelling reasons" that challenge the validity of the underlying conviction? Specifically, can a prisoner use a motion for compassionate release to raise claims of actual innocence or trial error? Whether such claims must instead be brought exclusively under the collateral review framework of 28 U.S.C. §2255.

Petitioner's argument
  • Doubts about the validity of a conviction, including claims of actual innocence, constitute "extraordinary and compelling reasons" warranting a sentence reduction under 18 U.S.C. §3582(c)(1)(A)(i).
  • The strict procedural limitations of 28 U.S.C. §2255 are sometimes unfair, and §3582 provides a necessary merits-based alternative to mitigate those errors.
  • Actual innocence claims must be cognizable under §3582 because such claims have not been held to state a ground for federal habeas relief absent an independent constitutional violation.
  • Because the relief sought under §3582 (sentence reduction) differs from the relief under §2255 (vacatur), the two statutes operate on different tracks.
Respondent's argument
  • Challenges to the validity of a conviction are not "extraordinary and compelling reasons" under 18 U.S.C. §3582(c)(1)(A).
  • Allowing such claims under §3582 would permit prisoners to "evade the collateral review structure" and the rigorous procedural constraints of 28 U.S.C. §2255.
  • Congress has specifically channeled attacks on the validity of confinement through the federal habeas corpus framework.
  • Not stated.
The decision
  • The Court held that a prisoner who collaterally attacks the validity of his conviction must proceed through 28 U.S.C. §2255, not 18 U.S.C. §3582.
  • The Court applied an "anticircumvention principle" derived from *Preiser v. Rodriguez*, *District Attorney’s Office for Third Judicial Dist. v. Osborne*, and *Gonzalez v. Crosby*, holding that claims "close to the core of habeas corpus" must be brought under the specific habeas statute to avoid frustrating congressional intent.
  • The Court reasoned that §3582's "extraordinary and compelling reasons" standard does not encompass conviction validity because "extraordinary" means "most unusual" and "compelling" means "tending to convince or convert by or as if by forcefulness of evidence," and a reason is not compelling if Congress has already channeled it through postconviction statutes.
  • The Court noted that the name "Compassionate Release" and the focus on "terminal illness" (§3582(d)), elderly prisoners (§3582(c)(1)(A)(ii)), and rehabilitation (28 U.S.C. §994(t)) indicate the statute is designed for granting mercy rather than righting legal wrongs.
  • The Court emphasized the role of the Bureau of Prisons, noting that the Bureau's institutional expertise lies in the daily lives of prisoners—specifically "safekeeping," "care," "subsistence," "protection," "instruction," and "discipline" (18 U.S.C. §4042(a))—rather than in combing trial records for legal errors.
  • The Court observed that the Sentencing Commission's regulatory history has never identified the invalidity of a conviction as an "extraordinary and compelling reason" for release.
  • The Court found a "mismatch" between the alleged error and the remedy, stating that if a conviction is invalid, the fitting remedy is to vacate it under §2255, and the fact that §3582 does not offer vacatur is evidence that it is not a suitable vehicle for the claim.
  • The Court rejected the "actual innocence" exception, citing *Herrera v. Collins* to conclude that asserting actual innocence is a challenge to the validity of a conviction and thus falls under the habeas umbrella.
Separate opinions
Sotomayor, concurring (joined by Kagan)
  • Argues the majority's habeas-based rule is "atextual" and "unworkable" because it is found nowhere in the text of §3582(c)(1)(A).
  • Contends the judgment should be affirmed because a motion for compassionate release cannot justify a reduced sentence if it relies solely on facts already considered at sentencing rather than "changed circumstances" that developed after sentencing, citing *Setser v. United States*.
Jackson, dissenting
  • Argues §3582(c)(1)(A) is a flexible "safety valve" and that the majority's categorical exclusion of conviction-related concerns finds no support in the statute's text or history.
  • Asserts that a claim of actual innocence is the "quintessential" extraordinary and compelling reason and that §3582 operates as a matter of grace (discretionary) whereas §2255 operates as a matter of law (mandatory).