Rutherford v. United States

When Congress makes a sentencing reduction non-retroactive—meaning it applies only to future offenders and not to those already sentenced—the gap between an old sentence and what a defendant would receive under the new law cannot qualify as an "extraordinary and compelling reason" to grant compassionate release under 18 U.S.C. §3582(c)(1)(A)(i). Justice Amy Coney Barrett authored the 6-3 majority opinion of the Court. The compassionate release statute permits a court to reduce a prison sentence only when "extraordinary and compelling reasons" warrant it. "Extraordinary" means highly unusual or without precedent; "compelling" means convincingly forceful. A sentencing disparity created by a nonretroactive law change satisfies neither definition. Non-retroactivity is the default rule in federal law—changes to criminal penalties ordinarily benefit only future offenders, and any resulting gap between sentences is a routine, expected feature of the system, not something exceptional. Nor can the disparity be "compelling": Congress deliberately withheld the reduced penalties from already-sentenced defendants to protect finality and reduce court burdens, so allowing that deliberate choice to serve as a reason to undo a sentence would directly contradict Congress's judgment. The long-established core of compassionate release has always centered on a prisoner's personal circumstances—terminal illness, declining health, age, family emergencies—and a sentencing gap caused by a later law change falls entirely outside that tradition. The Sentencing Commission's 2023 policy statement, which added "Unusually Long Sentence" as a potential ground for compassionate release and permitted courts to consider nonretroactive law changes in narrow circumstances, does not alter this result. Congress empowered the Commission to define "extraordinary and compelling reasons," but those definitions must be consistent with the governing statute. Because the statute's plain text forecloses treating a nonretroactive sentencing change—alone or combined with other factors—as a qualifying reason, the Commission's policy statement exceeds its authority and is invalid to that extent. Before a court may consider the broader §3553(a) sentencing factors (a checklist Congress requires courts to weigh when sentencing, covering things like the nature of the offense and the need to avoid disparities), a prisoner must first clear the "extraordinary and compelling" eligibility threshold. That gatekeeping step is a distinct, mandatory requirement, not a free-form inquiry, and the disparity at issue here cannot clear it. Justice Sonia Sotomayor dissented, joined by Justices Elena Kagan and Ketanji Brown Jackson, arguing that Congress expressly delegated to the Sentencing Commission the authority to define "extraordinary and compelling reasons," the Commission reasonably exercised that authority through its 2023 policy statement by allowing courts to consider sentencing disparities only in narrow, case-by-case circumstances, and the majority improperly substituted its own statutory interpretation for the Commission's reasonable judgment.