Fernandez v. United States

A prisoner who wants to challenge the validity of his conviction after sentencing must use the federal habeas corpus statute, 28 U.S.C. §2255—not the compassionate release statute, 18 U.S.C. §3582—because doubts about a conviction's validity do not qualify as "extraordinary and compelling reasons" for early release. Justice Amy Coney Barrett authored the majority opinion of the Court. Congress built a strict procedural framework into §2255—the law governing post-conviction (after sentencing) challenges to federal convictions—including a one-year filing deadline, a general rule allowing only one attempt at relief, and a bar on relitigating already-rejected arguments. These constraints reflect a deliberate congressional choice. Permitting prisoners to route the same arguments through the compassionate release statute would let them bypass every one of those limits, filing conviction challenges repeatedly, years after the conviction became final, even on issues courts had already decided. Prior decisions, Preiser v. Rodriguez and Gonzalez v. Crosby, establish the controlling principle: when a claim goes to the heart of whether a prisoner's confinement is lawful, Congress's decision to channel that claim through the specific habeas statute overrides other statutes whose language might literally seem to allow it. Applying that same logic here, §3582 must be read in harmony with §2255, not as a workaround around it. The text and design of §3582 independently confirm this result. Compassionate release—as its name signals—exists to extend mercy based on a prisoner's personal circumstances, not to correct legal errors. Congress calibrated the statute around conditions like terminal illness, advanced age, and rehabilitation: factors the Bureau of Prisons can meaningfully assess from its expertise in daily prison life. It makes no sense for the Bureau to evaluate trial records and legal arguments about wrongful convictions. The word "compelling" is also context-dependent: a strong argument for one type of relief is not automatically a strong argument for a different type. Because Congress already created a specific process for conviction challenges, a claim that falls short of §2255's requirements is not "compelling" grounds for compassionate release. And the remedy mismatch clinches the point—if a conviction is genuinely invalid, the appropriate fix is to vacate it, as §2255 allows, not to shorten the sentence while leaving the conviction intact. Justice Sonia Sotomayor concurred in the judgment (joined by Justice Elena Kagan), agreeing the District Court erred but arguing the majority's habeas-based rule is an atextual overreach that risks blocking meritorious claims; in her view, the correct and far simpler ground for affirmance is that a compassionate release motion cannot succeed when it relies solely on facts a court already considered at sentencing, rather than on changed circumstances that arose afterward. Justice Ketanji Brown Jackson dissented, arguing the majority grafts a restriction onto §3582 that appears nowhere in the statute's text or history, misapplies Preiser and Gonzalez (which involved general civil statutes, not a specific criminal sentencing provision), and leaves actually innocent prisoners with no avenue for relief, contradicting Congress's intent to create compassionate release as a flexible safety valve for extraordinary injustice.