Fernandez v. United States
No. 24-556 · Decided May 28, 2026 · affirmed
Does 18 U.S.C. § 3582(c)(1)(A) 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, not 18 U. S. C. § 3582.
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).
The question
Does 18 U.S.C. § 3582(c)(1)(A) 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 argue that he is actually innocent or that his conviction was wrongful? The Court must determine if such challenges are cognizable under § 3582 or if they must be brought 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" for a sentence reduction under 18 U. S. C. § 3582(c)(1)(A).
- Because § 3582 seeks a sentence reduction rather than the vacatur of a conviction provided by 28 U. S. C. § 2255, the two statutes offer different forms of relief and can coexist.
- 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.
- The "extraordinary and compelling" standard is flexible and should allow courts to mitigate unfairness when a prisoner cannot meet the "legal intricacies" of *Brady v. Maryland* or *Strickland v. Washington*.
Respondent's argument
- Challenges to the validity of a conviction are not cognizable as "extraordinary and compelling reasons" under 18 U. S. C. § 3582(c)(1)(A).
- Congress has channeled collateral attacks on the validity of federal convictions exclusively through the procedural framework of 28 U. S. C. § 2255.
- Allowing such claims under § 3582 would permit prisoners to evade the strict procedural constraints of § 2255, such as the one-year statute of limitations and the bar on successive petitions.
- The purpose of "Compassionate Release" is to grant mercy based on personal circumstances, not to right legal wrongs or re-evaluate trial evidence.
The decision
- The Court held that a prisoner attacking the validity of his conviction must proceed through 28 U. S. C. § 2255, as the supposed invalidity of a conviction is not an "extraordinary and compelling reason" justifying compassionate release under 18 U. S. C. § 3582.
- The Court applied an "anticircumvention principle" derived from *Preiser v. Rodriguez* and *Gonzalez v. Crosby*, reasoning that prisoners cannot use general statutes or rules to bypass the rigorous requirements of the specific federal habeas corpus framework.
- The Court defined "extraordinary" as "most unusual" and "compelling" as "tending to convince or convert by or as if by forcefulness of evidence," noting that a reason is not "compelling" if Congress has already channeled that specific claim through postconviction statutes.
- The Court reasoned that the name "Compassionate Release" and the statutory focus on "terminal illness" (§ 3582(d)) and elderly prisoners (§ 3582(c)(1)(A)(ii)) indicate a focus on mercy rather than legal error.
- The Court noted that the Bureau of Prisons' role as the initial evaluator reflects a focus on "personal circumstances" (e.g., age, illness, rehabilitation) because the Bureau lacks the institutional expertise to "comb trial records" or evaluate legal arguments.
- The Court observed that the Sentencing Commission has historically tied compassionate release to personal circumstances and has never identified the invalidity of a conviction as a qualifying reason.
- The Court rejected the argument that the difference in relief (sentence reduction vs. vacatur) allows for a separate track, stating that if a conviction is invalid, the only fitting remedy is to vacate it under 28 U. S. C. § 2255.
- The Court concluded that claims of actual innocence "challenge the validity of [a] conviction" under *Herrera v. Collins* and thus lie "close to the core of habeas corpus" per *Preiser*.
Separate opinions
Sotomayor, concurring (joined by Kagan)
- Argues the majority's rule is "atextual" and based on "tenuous inferences" from habeas law.
- Proposes that the judgment should be affirmed on the ground that § 3582(c)(1)(A) requires "changed circumstances" that developed after sentencing, rather than a categorical ban on conviction attacks.
Jackson, dissenting
- Argues that § 3582(c)(1)(A) is a flexible "safety valve" and that the majority's restriction is an "unwarranted revision" of the statute.
- Contends that actual innocence is the "quintessential situation" for compassionate release and that the "anticircumvention principle" from *Preiser* and *Gonzalez* is inapposite because § 3582 is a specific criminal sentence-reduction mechanism, not a general civil provision.