Fernandez v. United States

P R E L I M I N A R Y P R I N T
Volume 608 U. S. Part 2
Pages 411–453
OFFICIAL REPORTS
OF
THE SUPREME COURT
May 28, 2026
REBECCA A. WOMELDORF
reporter of decisions
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pio@supremecourt.gov, of any typographical or other formal errors.

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OCTOBER TERM, 2025 411
Syllabus
FERNANDEZ v. UNITED STATES
certiorari to the united states court of appeals for
the second circuit
No. 24–556. Argued November 12, 2025—Decided May 28, 2026
Joe Fernandez was indicted in 2013 for his role in the assassination of two
gang members. The prosecution's theory was that members of a drug
ring had paid Fernandez to act as the backup shooter, and when the
primary shooter's gun jammed, Fernandez fred 14 rounds and killed
both victims. Fernandez's alleged co-conspirator, Patrick Darge, testi-
fed against Fernandez at trial. The jury convicted Fernandez of mur-
der for hire and a frearms offense, and the District Court imposed two
consecutive life sentences.
Fernandez pursued multiple avenues of relief. He frst asked the Dis-
trict Court to reconsider, alleging Brady violations related to the Gov-
ernment's failure to disclose that another alleged co-conspirator, Luis
Rivera, had denied driving the getaway car. The District Court re-
viewed the Government's notes from interviewing Rivera and concluded
that they did not contain relevant information, though the judge noted
he was “troubled” by the Government's lenient treatment of Rivera.
The Second Circuit affrmed the conviction and sentence, rejecting both
the Brady claim and Fernandez's insuffciency-of-evidence argument.
It held that a reasonable jury could credit Darge's testimony and that
the evidence was suffcient to support conviction. Fernandez then
twice moved for postconviction relief under 28 U. S. C. § 2255. The frst
motion, arguing actual innocence based on witness credibility, was de-
scribed by the Second Circuit as “plainly meritless.” The second suc-
ceeded only in vacating his frearms conviction based on United States
v. Davis, 588 U. S. 445, thus leaving in place Fernandez's murder-for-
hire conviction. In the order vacating the frearms conviction, the Dis-
trict Judge speculated that the Government had offered Rivera a lenient
plea deal because it “kn[ew] something” inconsistent with Darge's testi-
mony, and pointedly noted that if Fernandez's life sentence on the
murder-for-hire charge “were to be commuted, or held unlawful, [Fer-
nandez] would be released immediately.” 569 F. Supp. 3d 169, 174,
n. 4, 179.
Fernandez fnally fled a motion for compassionate release under 18
U. S. C. § 3582(c)(1)(A)(i), arguing that extraordinary and compelling
reasons—above all, that he was innocent—warranted a sentencing re-
duction. The District Court granted the motion, citing unease about

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412 FERNANDEZ v. UNITED STATES
Syllabus
whether Darge's testimony had been truthful, concerns about the Gov-
ernment's charging decisions, and doubts about the correctness of the
jury's verdict. The Second Circuit reversed, holding that challenges to
the validity of a conviction are not cognizable as “extraordinary and
compelling reasons” under § 3582(c)(1)(A). Seven circuits agree with
the Second Circuit on that legal issue, while two circuits take the
other side.
Held: 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 sup-
posed invalidity of a conviction is not among the “extraordinary and
compelling reasons” that justify compassionate release. Pp. 419–430.
(a) Section 2255 governs collateral attacks on federal convictions and
imposes tight procedural constraints, including: a 1-year statute of limi-
tations, § 2255(f); a general rule that prisoners get only one shot at col-
lateral relief with narrow exceptions, §§ 2255(h)(1)–(2); a bar on relitigat-
ing claims already raised and rejected on direct review, see Kaufman
v. United States, 394 U. S. 217, 227, n. 8; and procedural default rules
requiring demonstration of “ `cause' ” and “ `prejudice' ” or actual inno-
cence for claims not raised on direct review, Bousley v. United States,
523 U. S. 614, 622. This case arises because after Fernandez lost a chal-
lenge to his conviction under § 2255, he fled a motion presenting similar
arguments under 18 U. S. C. § 3582, which permits prisoners to seek
compassionate release from prison by showing “extraordinary and com-
pelling reasons” warrant early release. Unlike the procedural con-
straints on § 2255 claims, the sole procedural requirement imposed by
§ 3582 is that the prisoner must frst present his request to the Bureau
of Prisons.
The Court's precedents establish that claims “close to the core of ha-
beas corpus” must be brought under “the specifc federal habeas corpus
statute” prescribed for relief, Preiser v. Rodriguez, 411 U. S. 475, 489,
and other statutes “must be read in harmony” with the habeas frame-
work, District Attorney's Offce for Third Judicial Dist. v. Osborne, 557
U. S. 52, 66. In Preiser, the Court held that even though prisoners'
claims “came within the literal terms” of 42 U. S. C. § 1983, Congress's
determination “that habeas corpus is the appropriate remedy for state
prisoners attacking the validity of the fact or length of their confne-
ment” “must override the general terms of § 1983.” 411 U. S., at 490.
A contrary result would allow prisoners to evade the rigorous require-
ments of postconviction relief and “wholly frustrate explicit congres-
sional intent.” Id., at 489. In Gonzalez v. Crosby, 545 U. S. 524, the
Court held that prisoners may not use Federal Rule of Civil Procedure
60(b) to argue that a denial of habeas relief was wrong on the merits,
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Syllabus
because allowing such motions would permit movants to “circumvent”
the strict statutory habeas standards.
Applying these principles, challenging the validity of a conviction
through a compassionate release motion circumvents the exacting re-
quirements of § 2255. Fernandez candidly admits that avoiding § 2255's
procedural and substantive requirements is the beneft of his approach.
His strategy would enable prisoners to bypass § 2255 by challenging
convictions repeatedly, for years after they became fnal, and regardless
whether the issues had already been raised or decided in prior
proceedings.
The text and structure of § 3582 confrm that the invalidity of a convic-
tion is not among the “extraordinary and compelling reasons” justifying
compassionate release. “Extraordinary” means “most unusual,” “far
from common,” and “having little or no precedent,” Webster's Third
New International Dictionary 807, while “compelling” means “tending
to convince or convert by or as if by forcefulness of evidence,” id., at
463. An argument that is compelling in one context is not necessarily
so in another, and a reason is not “compelling” if Congress has channeled
it through the postconviction statutes. The name for § 3582(c)(1)(A)—
“Compassionate Release”—highlights its focus on granting mercy
rather than righting legal wrongs. Congress gives special protection
to defendants with “terminal illness,” § 3582(d); expressly identifes that
relief is available for elderly prisoners who have served lengthy sen-
tences and are not dangerous, § 3582(c)(1)(A)(ii); and has permitted the
Sentencing Commission to treat rehabilitation as a relevant consider-
ation, 28 U. S. C. § 994(t). The role of the Bureau of Prisons refects the
statute's focus on a defendant's personal circumstances such as advanced
age, safety risk, illness, and rehabilitation. The Bureau's institutional
expertise lies in the daily lives of prisoners, so it makes little sense to
have the Bureau evaluate legal arguments and comb trial records to
determine whether a prisoner has a “compelling” argument that his
conviction was wrongful. Regulatory history points the same way.
For decades, the Sentencing Commission has tied the availability of com-
passionate release to a defendant's personal circumstances and has never
said that the invalidity of a conviction can be an “extraordinary and
compelling reaso[n] warrant[ing]” compassionate release. Pp. 419–427.
(b) Fernandez's argument that § 2255 and § 3582 offer different forms
of relief does not help him. The difference in relief highlights the mis-
match between the error he alleges and the remedy he seeks. When a
prisoner persuades a court that his conviction is invalid, the remedy of
a little less prison time does not redress the wrong. If a conviction is
invalid, the ftting remedy is to vacate it, as § 2255 allows. Whether a
prisoner's request for relief serves as a challenge to a conviction often

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414 FERNANDEZ v. UNITED STATES
Syllabus
turns on the nature of the arguments presented. See, e.g., Gonzalez,
545 U. S., at 531, 533. If a prisoner moves for relief because of alleged
problems with the underlying criminal investigation or trial, his motion
suggests that his conviction is fawed. This case demonstrates as much:
The District Court found there was reason to question the verdict,
meaning that it harbored doubts about the soundness of the conviction.
Fernandez's backup argument—that actual innocence claims must be
cognizable under § 3582 because such claims have never been held to
state a ground for federal habeas relief absent an independent constitu-
tional violation—fails. No court has concluded Fernandez was actually
innocent. In any event, a prisoner asserting actual innocence “chal-
lenge[s] the validity of his conviction,” Herrera v. Collins, 506 U. S. 390,
406, and that lies “close to the core of habeas corpus,” Preiser, 411 U. S.,
at 489. Section 3582 does not provide a shortcut around the postconvic-
tion statutes. Pp. 427–430.
104 F. 4th 420, affrmed.
Barrett, J., delivered the opinion of the Court, in which Roberts,
C. J., and Thomas, Alito, Gorsuch, and Kavanaugh, JJ., joined. Soto-
mayor, J., fled an opinion concurring in the judgment, in which Kagan,
J., joined, post, p. 431. Jackson, J., fled a dissenting opinion, post, p. 433.
Benjamin Gruenstein argued the cause for petitioner.
With him on the briefs were Antony L. Ryan and Scott B.
Cohen.
Deputy Solicitor General Feigin argued the cause for re-
spondent. With him on the brief were Solicitor General
Sauer, Acting Assistant Attorney General Galeotti, Freder-
ick Liu, Tyler Anne Lee, and Andrew C. Noll.*
*Briefs of amici curiae urging reversal were fled for FAMM et al. by
Shelley Fite, Peter Goldberger, Joshua L. Dratel, Jessica Stengel, Daniel
Habib, Judith H. Mizner, Renee Pietropaolo, and Erica Zunkel; for Doug-
las Berman by Vincent Levy; and for Sen. Richard J. Durbin et al. by
Brent J. Gurney, David W. Ogden, and Daniel S. Volchok. Elizabeth B.
Wydra and Brianne J. Gorod fled a brief for the Constitutional Account-
ability Center as amicus curiae urging vacatur. Briefs of amici curiae
urging vacatur and remand were fled for the New York Council of De-
fense Lawyers (NYCDL) by Harry Sandick and Celeste L. M. Koeleveld;
and for Wolfgang Von Vader by Sarah P. Hogarth.
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Cite as: 608 U. S. 411 (2026) 415
Opinion of the Court
Justice Barrett delivered the opinion of the Court.
A federal statute authorizes district courts to shorten
prison sentences for “extraordinary and compelling rea-
sons”—most commonly, conditions like the prisoner's age and
infrmity. 18 U. S. C. § 3582(c)(1)(A). Petitioner Joe Fer-
nandez argues that doubts about a conviction's validity also
qualify as “extraordinary and compelling” reasons for relief
under the statute. We disagree. A prisoner who collater-
ally attacks the validity of his conviction must proceed
through 28 U. S. C. § 2255, not 18 U. S. C. § 3582.
I
Fernandez was indicted in 2013 for his role in the assassi-
nation of two gang members. The prosecution's theory was
that members of a drug ring had paid Fernandez $40,000 to
act as the backup shooter. When the primary shooter's gun
jammed, Fernandez stepped in. He fred 14 rounds, killing
both victims.
Fernandez's cousin and alleged co-conspirator, Patrick
Darge, testifed against him at trial. To discredit Darge,
Fernandez's counsel argued that Darge was framing Fernan-
dez to protect the real second shooter, Darge's brother. Un-
convinced, the jury convicted Fernandez of murder for hire
and a frearms offense. See 18 U. S. C. §§ 924( j), 1958. The
District Court then imposed two consecutive life sentences.
Fernandez asked the District Court to reconsider, alleging
that the prosecution had violated Brady v. Maryland, 373
U. S. 83 (1963). He pressed that argument several times,
frst in a motion to vacate the verdict, then in a motion for
new trial, and again in a motion for rehearing. According
to Fernandez, the Government should have disclosed that
another alleged co-conspirator, Luis Rivera, had denied driv-
ing the getaway car. To determine whether Rivera had in
fact denied his involvement, the District Court reviewed the
Government's notes from Rivera's interview; it concluded
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416 FERNANDEZ v. UNITED STATES
Opinion of the Court
that they “d[id] not contain any relevant information.”
United States v. Fernandez, 2014 WL 7180225, *1 (SDNY,
Nov. 25, 2014). There was no evidence that Rivera had ever
made such a statement, and it was not clear that it would
have mattered to the jury if he had. Even so, the judge
noted that he was “troubled” that prosecutors had “allow[ed]
Rivera to plead to a lesser narcotics offense and [had] dis-
miss[ed] the murder and gun charges against him.” Id., at
*3. In the judge's view, the prosecutors could have used the
evidence in Fernandez's case to show that Rivera had en-
gaged in similar wrongdoing. Ibid.
Fernandez appealed, and the Second Circuit affrmed his
conviction and sentence. See United States v. Fernandez,
648 Fed. Appx. 56 (2016). Although Fernandez argued that
the Government had failed to turn over its notes before trial,
those notes “d[id] not refect Rivera's unequivocal denial of
a getaway driver role.” Id., at 61. “[I]n any event,” the
court said, “Fernandez fails to show how the notes could
have been `useful' ” for impeaching any witness. Ibid.
Fernandez also argued that insuffcient evidence supported
his conviction: He insisted that Darge's testimony was not
credible and highlighted the Government's choice not to
charge Rivera as a co-conspirator in the murder-for-hire plot,
which he considered indicative of the weakness of the Gov-
ernment's case. But the court rejected the insuffciency
claim too. It held that a reasonable jury could credit
Darge's testimony, that it was corroborated by other evi-
dence in the record, and that the evidence was suffcient to
support Fernandez's conviction.
Fernandez persisted. He twice moved for postconviction
relief under 28 U. S. C. § 2255. The frst time, Fernandez ar-
gued (among other things) that he was actually innocent be-
cause the testimony against him was not credible. He said
that “[e]ven the Government did not fully believe Patrick
Darge,” as shown by the Government's decision not to charge
Rivera with murder for hire. Reply Brief in No. 18–06

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Opinion of the Court
(CA2), pp. 8–9, n. 2. The Second Circuit described this argu-
ment as “plainly meritless,” concluding that “[t]he jury was
entitled to credit the witnesses who testifed that Fernandez
committed the crimes with which he was charged.” Fer-
nandez v. United States, 757 Fed. Appx. 52, 55–56 (2018).
The second collateral challenge succeeded. The District
Court set aside Fernandez's conviction for a frearms offense
after United States v. Davis, 588 U. S. 445 (2019), held that
18 U. S. C. § 924(c)(3)'s residual clause is unconstitutionally
vague. See Fernandez v. United States, 569 F. Supp. 3d 169
(SDNY 2021).
Still, the District Judge remained troubled about Fernan-
dez's murder-for-hire conviction. No new evidence had sur-
faced. But the judge continued to focus on Rivera—the get-
away driver who had pleaded guilty to a less serious charge.
In his order vacating the frearms conviction, the judge spec-
ulated that the Government had offered Rivera such a le-
nient plea deal because it “kn[ew] something” inconsistent
with Darge's testimony. Id., at 174, n. 4. And if Darge was
lying, the judge wondered, “perhaps there is something to
Petitioner's argument, that not he, but Patrick Darge's
brother . . . was the second shooter, and that Patrick Darge
testifed to cover that up.” Ibid. Notably, the Second Cir-
cuit had already rejected this argument twice, and Fernan-
dez had not briefed it again before the District Court. But
the judge brought it up anyway, pointedly noting that if Fer-
nandez's life sentence on the murder-for-hire charge “were
to be commuted, or held unlawful, [Fernandez] would be re-
leased immediately.” Id., at 179.
Fernandez took the hint. Within two weeks, he fled a
motion for compassionate release under § 3582(c)(1)(A)(i).
See No. 1:10–cr–00863 (SDNY), ECF Doc. 248. He argued
that extraordinary and compelling reasons—above all, that
he was innocent—warranted a sentencing reduction. Ac-
cording to Fernandez, Darge's testimony was biased and un-
corroborated by forensic evidence; moreover, his identifca-
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418 FERNANDEZ v. UNITED STATES
Opinion of the Court
tion of Rivera as the getaway driver was inconsistent with
a later statement made by Rivera himself. The Government
had not turned over its notes on that statement, Fernandez
asserted, and had allowed Rivera to plead guilty to a lesser
charge.
The District Court granted the motion. Nearly a decade
after presiding over the trial and sentencing, the judge felt
“a certain disquiet” about whether Darge's testimony had
been truthful and whether the cross-examination had been
effective. 2022 WL 17039059, *4 (SDNY, Nov. 17, 2022).
He had “strong concerns” about the Government's decision
to charge the getaway driver with a lesser offense and
“doubt[ed] that the jury's verdict was correct. ” Ibid.
Darge might have “sacrifce[d]” Fernandez “to save his
brother,” and Fernandez might not have been the shooter or
even “a member of the conspiracy.” Ibid. That “disquiet”
formed the “basis of [the District Court's] fnding that Peti-
tioner Joe Fernandez has shown extraordinary and compel-
ling circumstances for his release.” Ibid.1
The Second Circuit reversed, holding that “challenges to
the validity of a conviction are not cognizable as `extraordi-
nary and compelling reasons' under section 3582(c)(1)(A).”
104 F. 4th 420, 431 (2024). Congress has channeled such
claims into federal postconviction proceedings under 28
U. S. C. § 2255, and by design, compassionate release and
§ 2255 do not overlap. “Challenging the validity of a convic-
tion under the extraordinary-and-compelling-reasons prong
of section 3582,” the court explained, “would permit a de-
fendant to `evade the collateral review structure' of section
2255.” 104 F. 4th, at 430 (alteration omitted).
1 The District Court also granted compassionate release based on the
sentencing “disparity between Fernandez'[s] life sentence and the sen-
tences of the co-defendants.” 2022 WL 17039059, *4. The Second Circuit
concluded that this was an error, 104 F. 4th 420, 429 (2024), and the issue
is not before us.
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Opinion of the Court
While seven other Circuits have reached the same conclu-
sion, two have taken the other side.2 We granted certiorari
to resolve the split. 605 U. S. 931 (2025).
II
Collateral attacks on federal convictions are governed by
28 U. S. C. § 2255, which imposes tight procedural con-
straints. It carries a one-year statute of limitations.
§ 2255(f). With very narrow exceptions, a prisoner gets only
one shot at collateral relief. §§ 2255(h)(1)–(2). Claims that
have already been raised and rejected on direct review typi-
cally cannot be relitigated in § 2255 motions. See Kaufman
v. United States, 394 U. S. 217, 227, n. 8 (1969); Reed v. Far-
ley, 512 U. S. 339, 358 (1994) (Scalia, J., concurring in part
and concurring in judgment). And claims not raised on di-
rect review are procedurally defaulted unless the prisoner
can demonstrate “ `cause' ” and “ `prejudice,' ” or else actual
innocence. Bousley v. United States, 523 U. S. 614, 622
(1998). If the prisoner clears these procedural hurdles,
he must demonstrate that the applicable substantive law en-
titles him to relief. Section 2255's companion statute,
28 U. S. C. § 2254, imposes similar constraints on state
prisoners.
Recall that Fernandez brought—and lost—a challenge to
his conviction under § 2255. This case arises from his mo-
tion presenting similar arguments under a different statute,
18 U. S. C. § 3582, which permits prisoners to seek compas-
sionate release from prison. In contrast to § 2255's reticu-
2 Compare United States v. Ferguson, 55 F. 4th 262, 270–272 (CA4 2022);
United States v. Escajeda, 58 F. 4th 184, 186–187 (CA5 2023); United
States v. West, 70 F. 4th 341, 346–348 (CA6 2023); United States v. Von
Vader, 58 F. 4th 369, 371 (CA7 2023); United States v. Crandall, 25 F. 4th
582, 586 (CA8 2022); United States v. Wesley, 60 F. 4th 1277, 1284–1286
(CA10 2023); United States v. Jenkins, 50 F. 4th 1185, 1202–1204 (CADC
2022), with United States v. Trenkler, 47 F. 4th 42, 48 (CA1 2022); United
States v. Roper, 72 F. 4th 1097, 1102–1103 (CA9 2023).
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420 FERNANDEZ v. UNITED STATES
Opinion of the Court
lated scheme, § 3582 imposes a single procedural require-
ment: A prisoner must frst present his request for release
to the Bureau of Prisons. § 3582(c)(1)(A). A motion may
then be fled in district court, where the prisoner (or the
Bureau, acting on his behalf) must show that “extraordinary
and compelling reasons” warrant his early release from con-
fnement. § 3582(c)(1)(A)(i).
This is not the frst time we have addressed the relation-
ship between the habeas statutes and other kinds of prisoner
litigation. In Preiser v. Rodriguez, prisoners brought
claims under 42 U. S. C. § 1983 challenging the forfeiture of
their good-time credits, and their claims “plainly came within
the literal terms of that statute.” 411 U. S. 475, 488 (1973).
Even so, we held that “[t]he broad language of § 1983” did
not afford the prisoners a cause of action. Id., at 489.
“Congress has determined that habeas corpus is the appro-
priate remedy for state prisoners attacking the validity of
the fact or length of their confnement, and that specifc de-
termination must override the general terms of § 1983.” Id.,
at 490. Challenges “close to the core of habeas corpus” must
be brought, if at all, under “the specifc federal habeas corpus
statute”—in that case § 2254—which was “explicitly and his-
torically designed to provide the means for a state prisoner
to attack the validity of his confnement.” Id., at 489. A
contrary result would allow prisoners to evade § 2254's re-
quirements, and so would “wholly frustrate explicit congres-
sional intent.” Ibid. That is why “§ 1983 must be read in
harmony with the habeas statute.” District Attorney's Of-
fce for Third Judicial Dist. v. Osborne, 557 U. S. 52, 66
(2009).
Gonzalez v. Crosby, 545 U. S. 524 (2005), fows in the same
vein. There, we held that prisoners may not use Federal
Rule of Civil Procedure 60(b) to argue that a denial of habeas
relief was wrong on the merits and warrants reopening.
The language of Rule 60(b) is expansive, permitting courts
to reopen a fnal judgment whenever a movant shows “any

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Opinion of the Court
. . . reason that justifes relief.” Fed. Rule Civ. Proc. 60(b)(6)
(emphasis added). And the text of § 2254 “did not expressly
circumscribe the operation of Rule 60(b).” Gonzalez, 545
U. S., at 529. Yet allowing movants to use a Rule 60(b) mo-
tion to make merits arguments would still collide with § 2254.
It would permit movants to “circumvent” the strict statutory
habeas standards, including “that a successive habeas peti-
tion be precertifed by the court of appeals.” Id., at 531–
532 (citing 28 U. S. C. § 2244(b)(3)). And the Rule could not
be applied to habeas proceedings in a manner “ `inconsistent
with' ” § 2254. 545 U. S., at 529 (quoting 28 U. S. C. § 2254
Rule 11 (2000 ed., Supp. IV)). Thus, Rule 60(b)'s allowance
of reopening for “any . . . reason” was narrowed to account
for § 2254.
Much like the prisoners in Preiser and Gonzalez, Fernan-
dez has pursued a collateral attack outside the rigorous ha-
beas framework. And as in those cases, the workaround
is impermissible. Challenging the validity of a conviction
through a compassionate release motion circumvents the ex-
acting requirements of § 2255.3
Indeed, Fernandez candidly admits that avoiding § 2255's
procedural and substantive requirements is the beneft of his
approach. As for procedure: Fernandez asserted at oral ar-
gument that “there are harsh limitations associated with
[§ ]2255, and Congress has stated . . . that those limitations
are appropriate, but it doesn't mean that in every case, as
3 The dissent dismisses Preiser and Gonzalez on the ground that § 1983
and Rule 60(b) are “general” provisions, whereas 18 U. S. C. § 3582(c)(1)(A)
is “specifc.” Post, at 446–448 (opinion of Jackson, J.). But Preiser and
Gonzalez do not lay the relevant statutes side-by-side to determine which
is more “general” than the other. (If that were the metric, § 3582(c)(1)(A)
is certainly “more general” than 28 U. S. C. § 2255.) Instead, both cases
apply an anticircumvention principle: They ask whether it would “imper-
missibly circumvent” the specifc design of the habeas statute to permit
prisoners to challenge the legality of their confnement through a statute
whose literal language might otherwise apply. Gonzalez, 545 U. S., at 532;
see also Preiser, 411 U. S., at 489. We undertake the same inquiry here.
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422 FERNANDEZ v. UNITED STATES
Opinion of the Court
applied to every defendant, that those limitations are fair.”
Tr. of Oral Arg. 18–19. According to Fernandez, the ability
to bring a merits-based challenge under § 3582 mitigates
“[t]he error and the unfairness of [the prisoner's] not having
been able to bring it under [§ ]2255.” Id., at 19. His take
on substance is similar. He offers the example of a prisoner
who claims that prosecutors withheld mitigating evidence
and that his lawyer was constitutionally ineffective for fail-
ing to pursue that evidence. Fernandez posits that these
arguments would fail to satisfy “the legal intricacies of the
doctrines related to Brady v. Maryland and Strickland v.
Washington.” Brief for Petitioner 41 (citation omitted).
Still, Fernandez asserts, these half-baked legal challenges
could count as “extraordinary and compelling reasons” that
justify a reduced sentence. Ibid. The dissent, too, pro-
claims that the “core mission” of compassionate release is to
offer deserving prisoners relief from the rigors of § 2255.
Post, at 452–453 (opinion of Jackson, J.).
It is easy to see why Fernandez would prefer this con-
struction. Section 3582—in sharp contrast to § 2255—im-
poses no time limit or numerical cap on motions. Nor is
there any bar to raising issues waived or already decided on
direct appeal. So a prisoner proceeding under § 3582 could
challenge the validity of his conviction repeatedly, for years
after it became fnal, even if the issue had already been
raised or decided in prior proceedings. This system would
enable prisoners not only to bypass § 2255, but also to over-
ride it. Consider this very case: Fernandez lost an argu-
ment on direct review and under § 2255, but then repackaged
it in a motion under § 3582(c)(1)(A)(i) and obtained release
from prison on those twice-rejected grounds.
We will not set § 3582 and § 2255 at cross-purposes when
we can construe them “in harmony.” District Attorney's
Offce, 557 U. S., at 66. Congress made compassionate re-
lease available only when “extraordinary and compelling rea-
sons” justify it. § 3582(c)(1)(A)(i). That is a demanding
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Opinion of the Court
standard. And as we did with § 1983 in Preiser and
Rule 60(b) in Gonzalez, we interpret § 3582 against the back-
drop of the detailed process that Congress “explicitly and
historically designed” for “attack[ing] the validity of [a pris-
oner's] confnement.” Preiser, 411 U. S., at 489; see also
Jones v. Hendrix, 599 U. S. 465, 473 (2023). Seen in that
light, the supposed invalidity of a conviction is not among
the “extraordinary and compelling reasons” that justify com-
passionate release.
While Congress has not defned the “extraordinary and
compelling reasons” that may warrant a reduced sentence,
these criteria are not empty vessels. “Extraordinary”
means “most unusual,” “far from common,” and “having little
or no precedent.” Webster's Third New International Dic-
tionary 807 (1976); see 5 Oxford English Dictionary 614 (2d
ed. 1989) (“[o]ut of the usual or regular course or order”).
“Compelling” means “tending to convince or convert by or
as if by forcefulness of evidence.” Webster's Third New In-
ternational Dictionary, at 463; see 3 Oxford English Diction-
ary, at 600 (“irresistible; demanding attention, respect”).
We will focus on the latter requirement.
An argument that is compelling in one context is not nec-
essarily so in another; the force of an argument depends on
what it seeks to justify. For instance, a 25th wedding anni-
versary is a convincing reason to shorten a business trip, but
it is not a convincing reason to shorten a prison sentence.
So here, we do not ask in the abstract whether a challenge
to the validity of a conviction is “compelling.” We ask
whether it is an especially convincing reason to grant the
relief sought: compassionate release from prison.4
4 The dissent acknowledges that it is “obviously true” that context in-
forms which reasons count as “compelling.” Post, at 436. The concur-
rence agrees, for it proposes another context-based limit: that only “changed
circumstances” qualify as reasons warranting sentencing reduction. Post,
at 431 (Sotomayor, J., concurring in judgment). Given that the concur-
rence embraces a limit that appears nowhere in the text, it is hard to see
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424 FERNANDEZ v. UNITED STATES
Opinion of the Court
Section 2255's reticulated scheme bears on this inquiry. A
reason is not “compelling” if Congress has channeled it
through the postconviction statutes. Even Fernandez rec-
ognizes that an argument may be less compelling if it could
have been—and was not—asserted through § 2255. He ad-
mits that courts may consider “as part of the extraordinary
and compelling analysis” whether a “defendant sat on his
rights or whether he's taken all opportunities to enforce his
rights.” Tr. of Oral Arg. 15–16. Yet the same is true for
§ 2255's other substantive and procedural requirements: That
Congress has chosen to make § 2255 a high bar is not a com-
pelling reason to reduce the sentences of prisoners who fall
short.
Other features of the statute point in the same direction.
The name for § 3582(c)(1)(A)—“Compassionate Release”—
highlights its focus on granting mercy rather than righting
legal wrongs. First Step Act of 2018, § 603(b), 132 Stat. 5239
(heading). In keeping with the theme of “compassion,” Con-
gress in § 3582 gives special protection to defendants with a
“terminal illness.” § 3582(d). For instance, the Director of
the Bureau of Prisons must notify terminally ill prisoners of
their right to seek compassionate release, §§ 3582(d)(2)(A)(i),
(B)(i); must sometimes assist in preparing those compassion-
ate release requests, §§ 3582(d)(2)(A)(iii), (B)(iii); and must
report to Congress “the number of prisoners who died while
their request was pending,” § 3582(d)(3)(H). In addition, the
statute expressly identifes one situation in which a sentenc-
ing reduction is warranted: when “the defendant is at least
70 years of age, has served at least 30 years” of a certain
type of mandatory life sentence, and the Director of the Bu-
reau of Prisons determines “that the defendant is not a dan-
ger to the safety of any other person or the commu-
nity.” § 3582(c)(1)(A)(ii). And in another statute that ref-
erences § 3582(c)(1)(A), Congress has permitted the Sentenc-
how the concurrence can resist our interpretation on the ground that it is
“atextual.” Post, at 431.
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Opinion of the Court
ing Commission to treat a defendant's rehabilitation as a rel-
evant consideration in granting compassionate release. 28
U. S. C. § 994(t).
The role of the Bureau of Prisons refects the statute's
focus on a defendant's personal circumstances—his advanced
age, safety risk, illness, rehabilitation, and the like. The Bu-
reau evaluates compassionate release motions in the frst in-
stance. Until 2018, a district court could reduce a sentence
only “ `upon motion of the Director of the Bureau of Pris-
ons.' ” Sentencing Reform Act of 1984, 98 Stat. 1998–1999.
After the First Step Act, prisoners may fle their own com-
passionate release motions, but only if the Bureau declines
or fails to respond to a prisoner's request that the Director
fle on his behalf. 132 Stat. 5239. Fernandez agrees that
this procedural shift in the Bureau's role—from exclusive
fler to initial evaluator—did not change the substantive
standard applicable to compassionate release motions. See
Tr. of Oral Arg. 9–12.
If compassionate release were a vehicle for attacking the
validity of a conviction, it is hard to see why the Bureau of
Prisons would run the process. The Bureau's institutional
expertise lies in the daily lives of prisoners: matters relating
to their “safekeeping,” “care,” “subsistence,” “protection,”
“instruction,” and “discipline.” 18 U. S. C. § 4042(a). So
it makes sense for the statute to instruct the Bureau to
help terminally ill prisoners seek compassionate release.
§ 3582(d). By contrast, it makes little sense to have the Bu-
reau evaluate legal arguments and comb trial records to de-
termine whether a prisoner has a “compelling” argument
that his conviction was wrongful. Even Fernandez concedes
that analyzing potential trial errors is outside the Bureau's
bailiwick. Tr. of Oral Arg. 10. Take Fernandez's own situ-
ation: How would the Bureau determine whether the testi-
mony at his trial was credible? Or take Fernandez's hypo-
thetical: How would the Bureau evaluate arguments raised
under Brady v. Maryland, 373 U. S. 83, and Strickland v.
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426 FERNANDEZ v. UNITED STATES
Opinion of the Court
Washington, 466 U. S. 668 (1984)? Supra, at 421–422.
Congress's decision to route compassionate release motions
through the Bureau strongly suggests that the “extraordi-
nary and compelling reasons warrant[ing]” compassionate
release must be reasons that the Director is competent to
assess. § 3582(c)(1)(A)(i).
Regulatory history points the same way. Congress has
authorized the Sentencing Commission to issue policy state-
ments about when compassionate release is warranted, 28
U. S. C. § 994(t), and these policy statements shape whether
courts may grant compassionate release motions, 18 U. S. C.
§ 3582(c)(1)(A). For decades, the Sentencing Commission
has tied the availability of compassionate release to a defend-
ant's personal circumstances. See United States Sentencing
Commission, Guidelines Manual App. C, Amdt. 698 (Nov.
2007) (USSG) (listing “ `extraordinary and compelling rea-
sons' ” to include “ `terminal illness,' ” “ `a permanent physical
or medical condition,' ” “ `[t]he death or incapacitation of the
defendant's only family members capable of caring for the
defendant's minor child,' ” or “ `other' ” reasons as deter-
mined by the Director of the Bureau of Prisons). While the
Sentencing Commission has issued more detailed policy
statements over the years, it has maintained the same basic
categories.5 See USSG § 1B1.13(1), comment., n. 1 (Nov.
2021). It has never said that the invalidity of a conviction
qualifes as an “extraordinary and compelling reaso[n] war-
rant[ing]” compassionate release. § 3582(c)(1)(A)(i).
In short, the structural inference of Preiser and Gonzalez
is borne out in § 3582 itself. The heartland “extraordinary
and compelling reasons” that might warrant an early release
from prison—age, illness, a child left with no guardian—bear
5 In 2023, the Sentencing Commission added a new category to the list of
“extraordinary and compelling” reasons: “ `Unusually Long Sentence[s].' ”
USSG Supp. to App. C, Amdt. 814 (Nov.). That amendment, while not
relevant here, exceeds the Commission's authority. Rutherford v. United
States, 608 U. S. 454, 472–473 (2026).
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Opinion of the Court
no resemblance to the grounds for relief under § 2255. Fer-
nandez cannot deploy § 3582 to blunt what he perceives to be
the sharp edges of § 2255.
III
Fernandez insists that because § 2255 and § 3582 offer dif-
ferent forms of relief, the structural inference from Preiser
and Gonzalez does not apply. Under § 2255, a court could
set aside Fernandez's conviction as if it never happened.
But Fernandez is not going for that—at least not in this
round. Now, he seeks the more modest relief permitted by
§ 3582: a reduced sentence. If he succeeds, he would leave
prison early, but his murder-for-hire conviction—along with
its collateral effects—would remain in place. That distinc-
tion, he says, means that he is not circumventing § 2255, but
rather proceeding on an entirely different track. See also
post, at 442–443 (Jackson, J., dissenting).
Instead of helping him, this argument highlights the mis-
match between the error Fernandez alleges and the remedy
he seeks. When an elderly or infrm prisoner is discharged
early, the reasons for release have nothing to do with the
lawfulness of the conviction—so it makes sense to leave it
in place. But when a prisoner persuades a court that his
conviction is invalid, the remedy of a little less prison time
does not redress the wrong. If a conviction is invalid, the
ftting remedy is to vacate it, as § 2255 allows. That § 3582
does not offer this remedy is evidence that it is not a suitable
vehicle for the claim.
In any event, the difference in relief does not render
Preiser irrelevant. The remedies were not identical in
Preiser either: The prisoner sought an injunction under
§ 1983 for the restoration of good-time credits, rather than
habeas relief. This formal distinction did not change our
analysis; what mattered was that Preiser brought a claim
“close to the core of habeas corpus.” 411 U. S., at 489.
When, as here, a prisoner “attack[s] the validity of his con-
fnement” and “seeks either immediate release from that con-
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428 FERNANDEZ v. UNITED STATES
Opinion of the Court
fnement or the shortening of its duration,” his claim belongs
under the umbrella of the postconviction statutes. Ibid.
And to be clear: Fernandez is challenging the validity of
his conviction, even though he is not asking to have it va-
cated or set aside. Whether a prisoner's request for relief
challenges a conviction turns on the nature of the arguments
presented. See, e. g., Gonzalez, 545 U. S., at 531, 533 (hold-
ing that only some arguments presented in a Rule 60(b) mo-
tion would improperly infringe on § 2254). When a prisoner
moves for compassionate release based on a terminal illness,
his motion does not suggest that his conviction is invalid.
But if a prisoner moves for relief because of alleged problems
with the underlying criminal investigation or trial, his mo-
tion suggests that his conviction is fawed. That is true
here: Fernandez's motion said he “would never commit” mur-
der for hire; questioned whether the District Judge would
have reached the same verdict as the jury; urged the court
not to credit Darge's testimony; alleged that the Government
failed to turn over or present to the jury “highly exculpa-
tory” notes from interviewing Rivera; and even argued that
Fernandez could suffciently show his actual innocence to
satisfy Schlup v. Delo, 513 U. S. 298 (1995), which governs
certain procedurally defaulted habeas claims. See ECF
Doc. 248, pp. 7–9, 14. The District Court then impermissibly
treated Fernandez's challenge to his conviction as an “ex-
traordinary and compelling reaso[n]” for sentencing reduc-
tion. 18 U. S. C. § 3582(c)(1)(A)(i). It expressed “[r]eason to
[q]uestion the [v]erdict,” “doubt that the jury's verdict was
correct,” and the belief that the prosecution distrusted the
testimony of its star witness. 2022 WL 17039059, *4. In
other words, the District Court harbored doubts about the
soundness of the conviction.6
6 Perplexingly, the dissent accuses us of failing to defne “what it means
for a prisoner to `collaterally attac[k] the validity of his conviction,' ” post, at
448–449 (alteration in original), and characterizes this limit as unworkable,
post, at 441, 448–451; see also post, at 431 (Sotomayor, J., concurring in judg-
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Cite as: 608 U. S. 411 (2026) 429
Opinion of the Court
Fernandez offers a backup position: Even if § 3582(c)(1)
(A)(i) does not ordinarily allow district courts to grant com-
passionate release for reasons that would support a § 2255
motion, he asserts that actual innocence claims are an excep-
tion. He points out that “a factual showing of actual inno-
cence `ha[s] never been held to state a ground for federal
habeas relief absent an independent constitutional viola-
tion.' ” Brief for Petitioner 41–42 (quoting Herrera v. Col-
lins, 506 U. S. 390, 400 (1993)). Thus, he says, such a claim
must be cognizable under § 3582; otherwise, a prisoner might
have nowhere to go. See also post, at 441–442, 449–450
(Jackson, J., dissenting).
It bears emphasis that this argument is only marginally
relevant to Fernandez himself. No court—not even the Dis-
trict Court that reduced his sentence—concluded that Fer-
ment). But we explain our holding in detail, and its application is
straightforward: There is an obvious distinction between a prisoner who
asserts that he should not have been convicted in the frst place and one
who asserts that his present circumstances warrant an exercise of compas-
sion. Cf. Gonzalez v. Crosby, 545 U. S. 524, 532 (2005) (requiring district
courts to distinguish between Rule 60(b) motions that attack “the sub-
stance of the federal court's resolution of a claim on the merits” and those
that raise “some defect in the integrity of the federal habeas proceed-
ings”). Indeed, we routinely require courts to draw much fner distinc-
tions than this. See, e. g., Esteras v. United States, 606 U. S. 185, 200,
and n. 9 (2025) (requiring sentencing courts to consider “the nature and
circumstances of the offense” but not the “ `need for the sentence imposed'
`to refect the seriousness of the offense' ”).
Betraying the weakness of its criticism, the dissent leans on a source
that offers no support. According to the dissent, our approach implicates
the “notoriously diffcult” exercise of deciding “when, under the Preiser
line of cases, a successful § 1983 action necessarily implies `the invalidity
of the plaintiff's conviction.' ” Post, at 448–449 (citing W. Baude, J. Gold-
smith, J. Manning, J. Pfander, & A. Tyler, Hart and Wechsler's The Federal
Courts and the Federal System 1687 (8th ed. 2025)). But this source de-
scribes the diffculty of determining when relief other than a release from
custody (for example, a damages award) would “necessarily imply the in-
validity of [the plaintiff's] conviction” within the meaning of Heck v. Hum-
phrey, 512 U. S. 477, 487 (1994). That issue has no bearing on today's case.

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430 FERNANDEZ v. UNITED STATES
Opinion of the Court
nandez was actually innocent. His evidentiary challenges
were repeatedly rejected, and the District Court reduced his
sentence because of “disquiet” about the conviction, not con-
fdence in Fernandez's innocence. 2022 WL 17039059, *4.
So even if an actual innocence claim were cognizable under
§ 3582, Fernandez would not beneft from it.
In any event, this case gives us no occasion to decide the
antecedent question whether a prisoner may assert a free-
standing actual innocence claim under § 2255. We have
never ruled that possibility out and do not do so now. See
Herrera, 506 U. S., at 417. Instead, we hold simply that a
compassionate release motion is not a vehicle for raising such
a claim. A prisoner asserting actual innocence “challenge[s]
the validity of his conviction,” id., at 406, whether factually
or legally, and that lies “close to the core of habeas corpus,”
Preiser, 411 U. S., at 489. If it is “not in substance a `habeas
corpus application,' ” it is “at least similar enough that failing
to subject it to the same requirements would” forge a path
for bypassing the postconviction statutes. Gonzalez, 545
U. S., at 531. And for the reasons we have already stated,
§ 3582 does not provide that kind of shortcut.
Fernandez's remaining arguments echo those presented in
another case, which we also decide today. See Rutherford
v. United States, 608 U. S. 454 (2026). Petitioners in both
cases contend that the phrase “extraordinary and compelling
reasons” vests courts with broad discretion to grant a pris-
oner compassionate release for virtually any reason whatso-
ever. We reject these arguments here for the same reasons
we reject them in Rutherford. Id., at 468–472. “While the
terms `extraordinary' and `compelling' leave room for judg-
ment, they are not so fexible as to encompass any consider-
ation.” Id., at 468.
* * *
The compassionate release provision is not a vehicle for
attacking the validity of a conviction. Accordingly, the
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Sotomayor, J., concurring in judgment
judgment of the Court of Appeals for the Second Circuit is
affrmed.
It is so ordered.
Justice Sotomayor, with whom Justice Kagan joins,
concurring in the judgment.
The First Step Act of 2018 expanded district courts' au-
thority to “reduce [a] term of imprisonment” upon a fnding
that “extraordinary and compelling reasons warrant such a
reduction” and that the reduced sentence is consistent with
traditional sentencing factors. 18 U. S. C. § 3582(c)(1)(A).
For many of the reasons explained in Justice Jackson's dis-
senting opinion, the Court's decision interpreting that provi-
sion today is wrong. The majority improperly narrows the
scope of § 3582(c)(1)(A) based on tenuous inferences drawn
from the federal habeas statutes. Its habeas-based rule dis-
torts and expands the Court's habeas-channeling cases, cre-
ating an atextual limitation found nowhere in § 3582(c)(1)(A).
In doing so, it superimposes a technical, and likely unwork-
able, habeas analysis on top of a sentence-reduction frame-
work that broadly calls for holistic review. Moreover, the
rule adopted today risks shutting out meritorious claims for
a sentence reduction simply because they might resemble, in
some amorphous way, a claim that might call into question a
sentence or conviction.
Even so, the judgment below should be affrmed on a dif-
ferent, far simpler ground, which follows much more natu-
rally from the statute before the Court: A motion for com-
passionate release cannot justify a reduced sentence if it
relies solely on facts a court already considered in imposing
the initial sentence, rather than any changed circumstances
that developed after sentencing.
In general, a “court may not modify a term of imprison-
ment once it has been imposed.” § 3582(c). Section 3582(c)
(1)(A) authorizes a limited departure from that rule of fnal-
ity when “extraordinary and compelling reasons” arise so as
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432 FERNANDEZ v. UNITED STATES
Sotomayor, J., concurring in judgment
to “warrant . . . a reduction” of the sentence imposed. For
a reason to “warrant” a change of a sentence, however, it
cannot have been a consideration that was part of the initial
sentencing determination to begin with. At the very least,
changing a sentence already imposed under § 3582(c)(1)(A)
requires something to have changed, after sentencing, in a
way that alters the sentencing calculus. See, e. g., Setser v.
United States, 566 U. S. 231, 242–243 (2012) (explaining that
§ 3582(c)(1)(A) provides for relief when “ `developments that
take place after the frst sentencing' produc[e] unfairness to
the defendant” (citation omitted)). Otherwise, district
courts would have indefnite authority to revise sentences
already imposed based on information and arguments that
were previously considered and rejected. Such authority
would seriously diminish the fnality of sentences required
by § 3582(c).
The District Court's grant of relief here ran afoul of this
principle. Petitioner Joe Fernandez has been litigating the
issues at the core of his § 3582(c)(1)(A) motion since his trial.
From the start, Fernandez has contended that the evidence
against him was weak and that the prosecution failed to
prove beyond a reasonable doubt that he (and not someone
else) committed the murders for which he was convicted.
He raised these issues at his trial, see ante, at 415, at his
sentencing, see App. 57–62, in a motion to reconsider his sen-
tence, see ante, at 415–416, and in a postconviction motion
under 28 U. S. C. § 2255, even though “[n]o new evidence had
surfaced,” ante, at 416–417. Each effort failed in the trial
court and on appeal. Yet these same arguments fnally
found success under § 3582(c)(1)(A) based on the District
Court's renewed feelings of “ `doub[t]' ” and “ `disquiet' ”
about the original trial evidence supporting Fernandez's jury
verdict. Ante, at 418.*
*As the majority notes, ante, at 418, n. 1, the District Court also relied
on a sentencing disparity between Fernandez and some of his codefendants
in granting relief, but the Second Circuit rejected that separate basis for

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Jackson, J., dissenting
This grant of relief was inappropriate given the absence
of any postsentencing developments, and the Court needed
to go no further to affrm the decision below. Unfortunately,
bad facts often make bad law, and so they did today. Cor-
rectly perceiving a problem with the District Court's grant
of relief, the majority responds with a rule that goes far be-
yond both what is needed to resolve this case and, worse,
what the text and relevant precedents can bear. Because I
do not agree with the majority's reasoning in support of its
decision to affrm the decision below, I concur only in the
judgment of the Court.
Justice Jackson, dissenting.
Section 3582(c)(1)(A) of Title 18 of the U. S. Code—known
as the compassionate-release statute—authorizes district
courts to reduce federal prison sentences under specifed cir-
cumstances. This case is about the scope of that authority.
By its terms, the compassionate-release statute is fexible,
permitting sentence reductions for “extraordinary and com-
pelling reasons.” 18 U. S. C. § 3582(c)(1)(A)(i). The breadth
of this language is no accident: It refects Congress's intent
to preserve some of the traditional discretion afforded to dis-
trict courts to ensure just treatment of defendants in crimi-
nal cases.
Today, the Court arbitrarily restricts that discretion by
grafting an atextual rule onto § 3582(c)(1)(A). It holds that
a district court may not base its “extraordinary and compel-
ling” fndings on any reason that “collaterally attacks the
validity” of the prisoner's conviction. Ante, at 415. Such
“attacks,” the majority says, must be brought through mo-
tions for habeas relief under 28 U. S. C. § 2255. Ibid. But
this restriction comes of out nowhere—it fnds no support in
the statute's text or history, nor can it be justifed by our
precedents.
relief on grounds unrelated to the question that this Court granted certio-
rari to review, 104 F. 4th 420, 428–429 (2024).
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434 FERNANDEZ v. UNITED STATES
Jackson, J., dissenting
What, then, explains the new categorical rule that the
Court adopts today? The answer appears to be the majori-
ty's intuition that the District Court's grant of petitioner Joe
Fernandez's compassionate-release motion qualifes as an
abuse of discretion under the circumstances presented here.
That may well be true—but not because of an implicit,
habeas-based limitation on the reach of § 3582(c)(1)(A).
Because the Court of Appeals erroneously relied on such
a habeas-based rule in reversing the District Court's grant of
compassionate release, and the majority now endorses that
approach, I respectfully dissent. I would vacate, rather
than affrm, the decision of the Court of Appeals.
I
The majority holds that the District Court erred in grant-
ing Fernandez's compassionate-release motion because
§ 3582(c)(1)(A) contains an implicit habeas-based limitation:
Sentence reductions that derive from purported “[c]ollateral
attacks on federal convictions” are not authorized. Ante, at
419. It is not clear whether the majority believes, on the
one hand, that conviction-related concerns can never be suf-
fciently “extraordinary and compelling” or, on the other,
that even if there are “extraordinary and compelling” rea-
sons to doubt the defendant's conviction, a sentence reduc-
tion is nevertheless unavailable.
What is evident is that, in devising this new rule, the ma-
jority devotes most of its analysis to describing the contours
of habeas relief under § 2255 and gives short shrift to the
text and history of § 3582(c)(1)(A). Had the majority fo-
cused instead on the statute actually before it, it would have
seen that the compassionate-release provision operates as an
independent stop-gap measure, designed to preserve a dis-
trict court's discretion to reduce a criminal sentence when
“extraordinary and compelling” circumstances warrant that
result. And when § 3582(c)(1)(A) is thus properly under-
stood, it is clear that the existence of habeas review has no
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Jackson, J., dissenting
bearing whatsoever on whether a defendant can seek or ob-
tain compassionate release.
A
Start with the words Congress used in § 3582(c)(1)(A)—
they provide the most obvious strike against the majority's
newfound rule. Section 3582(c)(1)(A)'s text, while authoriz-
ing a sentence reduction, does not refer to § 2255 or habeas
review—in any way, shape, or form. Of course, if Congress
had intended § 2255 to limit the availability of the
compassionate-release remedy, it could easily have said so.
This Court has often taken the lack of a cross-reference to
mean that two distinct statutory provisions bear no relation
to one another. See, e. g., Pugin v. Garland, 599 U. S. 600,
608 (2023); Azar v. Allina Health Services, 587 U. S. 566,
576–577 (2019).
Not only is there no explicit basis for the majority's ha-
beas-based rule, there is also no implicit one. Section
3582(c)(1)(A) is a straightforward grant of discretion: It vests
district courts with authority to reduce a prisoner's sentence
for “extraordinary and compelling reasons.” The terms “ex-
traordinary” and “compelling” are commonly understood to
relate to a narrow and specifc set of circumstances defned
by degree, not type. See Rutherford v. United States, 608
U. S. 454, 480 (2026) (Sotomayor, J., dissenting). As the
majority acknowledges, “ `[e]xtraordinary' means `most un-
usual,' `far from common,' and `having little or no prece-
dent,' ” while “ `compelling' means `tending to convince or
convert by or as if by forcefulness of evidence.' ” Ante, at
423 (quoting Webster's Third New International Dictionary
463, 807 (1976)). Neither defnition implies the exclusion of
any kind of consideration from a district court's sentence-
reduction analysis. Rather, they suggest that any factor
can be the basis for compassionate release, so long as it
is both suffciently unusual and suffciently forceful. See
Romag Fasteners, Inc. v. Fossil Group, Inc., 590 U. S. 212,
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436 FERNANDEZ v. UNITED STATES
Jackson, J., dissenting
215 (2020) (observing that this Court does not “usually read
into statutes words that aren't there”).
The statutory context confrms the absence of any type-
based restriction on the sentence-modification authority
§ 3582(c)(1)(A) conveys, much less the majority's preferred
habeas limit. With full awareness of § 2255, Congress
placed only two textual limitations on what constitutes an
“extraordinary and compelling reason” to modify a defend-
ant's sentence. First, the resulting sentence reduction must
be “consistent” with the Sentencing Commission's policy
statements. 18 U. S. C. § 3582(c)(1)(A). Second, “[r]ehabili-
tation of the defendant alone shall not be considered an
extraordinary and compelling reason” for a sentence reduc-
tion. 28 U. S. C. § 994(t). Far from connoting an additional
habeas-based constraint, Congress's express inclusion of
these two restrictions on a district court's “extraordinary
and compelling” fndings “ `implies the exclusion of othe[r]' ”
such limitations. Jennings v. Rodriguez, 583 U. S. 281, 300
(2018) (quoting A. Scalia & B. Garner, Reading Law 107
(2012)).
The majority offers little by way of a text-based comeback.
Focusing on the word “compelling,” the majority observes
that what “is compelling in one context is not necessarily so
in another”; for example, a 25th wedding anniversary may
be a “compelling” reason to shorten a business trip but not
a prison sentence. Ante, at 423. While obviously true, that
observation tells us nothing relevant. All agree that per-
sonal considerations (e. g., illness and family hardship) might
warrant a sentence reduction under § 3582(c)(1)(A), see ante,
at 423–425, yet those considerations, too, are more or less
“compelling” under various circumstances. Moreover, as ex-
plained in Part II–A, infra, Fernandez's claim of actual inno-
cence, if meritorious, would be a compelling reason to reduce
his sentence. At the time the District Court considered his
§ 3582(c)(1)(A) motion, Fernandez had already served 11
years in federal prison for a crime he says he did not commit.
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Jackson, J., dissenting
On the “extraordinary and compelling reasons” scale, his in-
nocence claim is lightyears away from reducing a sentence
to facilitate celebration of a wedding anniversary.
B
The text alone suffces to dispel the habeas-related limita-
tion myth the majority adopts today. But, as is often true
of statutes, it is not possible to fully understand the
compassionate-release provision without appreciating its
statutory and legislative history. See R. Katzmann, Judging
Statutes 31 (2014) (“The task of the judge is to make sense
of legislation in a way that is faithful to Congress's pur-
poses”). The historical context under which § 3582(c)(1)(A)
emerged and developed is “the water in which [the text]
swim[s].” United States v. Hansen, 599 U. S. 762, 775 (2023).
Notably absent from this history is any indication that Con-
gress understood § 2255 to implicitly limit the scope of com-
passionate release, either when it frst enacted § 3582(c)(1)(A)
in 1984 or when it amended the provision in 2018.
1
Before 1984, “the Federal Government employed in crimi-
nal cases a system of indeterminate sentencing.” Mistretta
v. United States, 488 U. S. 361, 363 (1989). Though “[s]tat-
utes specifed the penalties for crimes,” they “nearly always
gave the sentencing judge wide discretion to decide whether
the offender should be incarcerated and for how long” or
“whether restraint, such as probation, should be imposed in-
stead of imprisonment or fne.” Ibid. The result: “great
variation among sentences imposed by different judges upon
similarly situated offenders” and “uncertainty as to the time
the offender would spend in prison.” Id., at 366.
Congress set out to alleviate those problems with the Sen-
tencing Reform Act of 1984. See 98 Stat. 1987; see also
S. Rep. No. 98–225, p. 65 (1983) (“The shameful disparity in
criminal sentences is a major faw in the existing criminal
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438 FERNANDEZ v. UNITED STATES
Jackson, J., dissenting
justice system, and makes it clear that the system is ripe for
reform”). The Act's most prominent reform was the cre-
ation of the U. S. Sentencing Commission, which Congress
tasked with promulgating a new, determinate system of Sen-
tencing Guidelines. See § 217(a), 98 Stat. 2017 (codifed at
28 U. S. C. § 991). Initially, the Guidelines were “binding on
the courts.” See Mistretta, 488 U. S., at 367–368. Judges
had some discretion to depart from an applicable Guidelines
range, but only after “fnd[ing] an aggravating or mitigating
factor present that the Commission did not adequately con-
sider.” Id., at 367.1
By design, the new Guidelines-based system left little
room for judges to exercise discretion when determining the
applicable sentence. See S. Rep. No. 98–225, at 38 (describ-
ing the new system as aimed at eliminating “the unfettered
discretion the law confers” on sentencing judges). At the
same time, Congress recognized that removing all discretion
would result in unfairly harsh sentences for some prisoners.
Indeed, despite the uniformity aim of the Guidelines, law-
makers acknowledged the possibility of an “exceptional situ-
ation where someone obviously slips through the cracks and
gets a much longer sentence.” Hearings on Revision of the
Federal Criminal Code before the Subcommittee on Criminal
Justice of the House Committee on the Judiciary, 96th Cong.,
1st Sess., pt. 3, pp. 1842–1843 (1979) (Code Revision Hear-
ings) (statement of Rep. Lungren). Federal judges similarly
warned of “those occasional cases which cry out for some
sort of revision, even though the sentence on that particular
1 Today, of course, the Guidelines are no longer binding—though district
courts must still “consult” and “take them into account when sentencing.”
United States v. Booker, 543 U. S. 220, 264 (2005). The Guidelines thus
“remain a basis for almost all federal sentences.” Hughes v. United
States, 584 U. S. 675, 688 (2018); see Peugh v. United States, 569 U. S. 530,
543 (2013) (observing that, “[e]ven after Booker rendered the Sentencing
Guidelines advisory,” courts overwhelmingly “imposed either within-
Guidelines sentences or sentences that depart downward from the Guide-
lines on the Government's motion”).
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Jackson, J., dissenting
offender has been imposed by a perfectly conscientious sen-
tencing court . . . and based upon facts and circumstances
which were a matter of record.” See id., at 1902–1903
(statement of Hon. Harold R. Tyler).
This problem was what Congress set out to address when
it created various “ `safety valve[s]' ” on the back end of the
sentencing process, allowing district courts to exercise their
discretion to reduce sentences in “unusual case[s].” S. Rep.
No. 98–225, at 121. The compassionate-release provision
was one of them. As enacted in 1984, § 3582(c)(1)(A) permit-
ted the Director of the Bureau of Prisons (BOP) to petition
a sentencing court for a reduction in a prisoner's sentence.
§ 212(a)(2), 98 Stat. 1998–1999. And it authorized a court to
grant such a petition if, “ `after considering the factors set
forth in section 3553(a),' ” the court found “ `that extraordi-
nary and compelling reasons' ” justifed the reduction and
that such a reduction was “ `consistent with applicable policy
statements issued by the Sentencing Commission.' ” Ibid.
Signifcantly for present purposes, Congress was well
aware of § 2255 in 1984. See, e. g., S. Rep. No. 98–225, at 234
(cross-referencing § 2255 in explaining a different provision
of the Sentencing Reform Act). But it never suggested that
§ 3582(c)(1)(A) and § 2255 were mutually exclusive, much less
that habeas was the sole means of obtaining postsentencing
relief from an unjust conviction. Nor did Congress indicate
that the availability of compassionate release hinged on the
unavailability of habeas review. Instead, it was clear from
the start that compassionate release was a distinct vehicle
for addressing potential inequities with respect to a defend-
ant's sentence: one specifcally designed to allow for the fex-
ible consideration of “extraordinary and compelling” circum-
stances notwithstanding the restrictions that otherwise
made the sentencing system less discretionary. Id., at 121
(recognizing the “value” of “assur[ing] the availability of spe-
cifc review and reduction of a term of imprisonment for
`extraordinary and compelling reasons' ”).
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Jackson, J., dissenting
2
But, as it turned out, the compassionate-release safety
valve rarely opened in the decades following § 3582(c)(1)(A)'s
enactment. Between 2006 and 2011, an average of “only 24
inmates” were “released each year through the BOP's com-
passionate release program.” Dept. of Justice, Offce of In-
spector General, The Federal Bureau of Prisons' Compas-
sionate Release Program 1 (Apr. 2013). Over time, it
became clear that BOP was drastically underutilizing its
compassionate-release power, “resulting in inmates who may
[have been] eligible candidates for release not being consid-
ered.” Id., at 11.
Of particular issue was the BOP's exceedingly narrow in-
terpretation of the statutory phrase “extraordinary and com-
pelling,” which its Central Offce staff had interpreted as
referring only to “terminally ill medical conditions with a life
expectancy of 1 year or less or those who are incapacitated
and unable to perform their daily activities—criteria that
[were] found nowhere in the relevant statute.” Id., at 13.
And though BOP regulations technically “permit[ted] non-
medical circumstances to be considered as a basis for
compassionate release,” the agency “routinely reject[ed]
such requests.” Id., at ii.
Congress took notice. In 2017, a bipartisan group of Sena-
tors wrote to the Department of Justice and expressed
“dee[p] concer[n] that BOP [was] not fulflling its role in the
compassionate release process.” Letter from 12 U. S. Sena-
tors to J. Rod Rosenstein, Deputy Attorney General, & Dr.
T. Kane, Acting BOP Director 3 (Aug. 3, 2017) (Letter from
12 U. S. Senators). Several of those Senators worked to-
gether later that year to introduce a “bipartisan sentencing
and prison reform bill” known as the First Step Act, which
passed the following year. 164 Cong. Rec. S7645 (Dec. 17,
2018) (statement of Sen. Durbin); see 132 Stat. 5194. In
a section entitled “Increasing the Use and Transparency
of Compassionate Release, ” the Act amended the
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compassionate-release provision to allow prisoners to fle
their own motions for sentence reductions, without approval
from the BOP. § 603(b), 132 Stat. 5239.
This historical account can be summarized succinctly.
Congress crafted § 3582(c)(1)(A) to operate as a safety valve
that would ameliorate the harshness of the new determinate
scheme for sentencing. S. Rep. No. 98–225, at 121. It was
not linked to, or limited by, the existence of habeas review
in any respect. And that made perfect sense given the spe-
cifc role Congress envisioned for compassionate release:
allowing a discretionary sentence modifcation for a prisoner
who presents “extraordinary and compelling” grounds for
mercy.
II
A
The majority nevertheless insists on categorically exclud-
ing one potential ground for compassionate release—any con-
sideration that supposedly “attacks the validity of [a] convic-
tion” or sentence. Ante, at 415. One glaring faw with this
analysis is the majority's failure to clearly establish when
this forbidden circumstance arises; that is, what, exactly,
does it mean for a prisoner to collaterally attack his convic-
tion in the context of a compassionate-release motion? It is
not hard to see how one man's collateral attack is another
man's compelling bid for compassion.
Consider, for example, an actually innocent defendant—
let's call him Paul. Paul is serving a life sentence and, for
reasons beyond his control, failed to discover indisputably
exonerating evidence during his trial. But Paul cannot
point to any way in which his conviction or sentence violates
the Constitution or some other provision of the U. S. Code.
He does not allege, for instance, that his counsel was ineffec-
tive or that the prosecution withheld exculpatory evidence.
Habeas thus provides no avenue for relief. See 28 U. S. C.
§ 2255(a) (authorizing relief for a defendant whose “sentence
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Jackson, J., dissenting
was imposed in violation of the Constitution or laws of the
United States”).
An innocent man stuck in prison for life: Can there be a
more “extraordinary and compelling” reason to shorten a
prison sentence than that? And is there any logical reason
to believe that Congress meant to prohibit Paul from peti-
tioning the court for such relief under § 3582(c)(1)(A)? Quite
to the contrary, this manifest injustice would seem to be the
quintessential situation in which the compassionate-release
safety valve would apply. See Code Revision Hearings, at
1842–1843 (statement of Rep. Lungren) (expressing concern
about federal prisoners “slip[ping] through the cracks”).
But the majority's rule would forbid it, simply and solely
because § 2255 exists.
Of course, this is not to say that every assertion of inno-
cence will necessarily qualify as an “extraordinary” or “com-
pelling” basis for a sentence reduction. For instance, a
claim of innocence that simply rehashes the evidence pre-
sented at trial is unlikely to suffce. The concern that Fer-
nandez is making such an unjustifed innocence claim seems
to be what drives much of the majority's analysis today. See
ante, at 429–430 (“No court—not even the District Court
that reduced his sentence—concluded that Fernandez was
actually innocent. His evidentiary challenges were repeat-
edly rejected”); see also ante, at 432 (Sotomayor, J., concur-
ring in judgment) (“Petitioner Joe Fernandez has been liti-
gating the issues at the core of his § 3582(c)(1)(A) motion
since his trial”). But the Court overcorrects for this con-
cern and, in the process, adopts an atextual rule that cate-
gorically forbids any consideration of potential innocence
whatsoever—no matter how extraordinary or compelling—
either on its own or as part of a mix of other considerations.
That result certainly does not follow from the text.
Nor would allowing consideration of potential innocence
permit federal prisoners to circumvent § 2255's limitations on
habeas relief, as the majority claims. See ante, at 420–423.
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Jackson, J., dissenting
That is because the habeas and compassionate-release provi-
sions operate differently. To be sure, both statutes author-
ize the release of federal prisoners. But, where the statu-
tory prerequisites are met, relief under § 3582(c)(1)(A) is
discretionary, whereas relief under § 2255 is mandatory: The
former provides that “the court . . . may reduce the term of
imprisonment,” while the latter states that “the court shall
vacate and set the judgment aside.” (Emphasis added.)
Section 3582(c)(1)(A) thus provides no guaranteed end-run
around § 2255's limitations on relief.
Section 3582(c)(1)(A) and § 2255 also differ in the nature
of the relief that they provide. Most notably, the grant of
compassionate release—even on actual-innocence grounds—
does nothing to invalidate the underlying conviction. A
neighboring subsection explicitly clarifes that compassion-
ate release does not disturb the fnality of the “judgment of
conviction.” § 3582(b). Not so with habeas—when a § 2255
applicant successfully challenges the validity of his convic-
tion, the result is vacatur. See § 2255(b) (“If the court fnds
. . . that there has been such a denial or infringement of the
constitutional rights of the prisoner as to render the judg-
ment vulnerable to collateral attack, the court shall vacate
and set the judgment aside” (emphasis added)).
Put differently, habeas nullifes a conviction as a matter of
law, while compassionate release shortens a sentence as a
matter of grace. The majority does not adequately explain
why these two forms of relief—which operate differently,
exist for different reasons, and ultimately yield different re-
sults—must necessarily work to the exclusion of each other.
B
Despite these crucial observations, the majority forges
ahead, insisting on grafting a habeas-based restriction onto
the compassionate-release remedy. It gets there in two
ways: frst, by overstating the signifcance of the BOP's role
in order to bolster the conclusion that “personal circum-

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444 FERNANDEZ v. UNITED STATES
Jackson, J., dissenting
stances” are the only cognizable factors under § 3582(c)(1)(A);
and, second, by overreading two of our prior habeas-
channeling cases—Preiser v. Rodriguez, 411 U. S. 475 (1973),
and Gonzalez v. Crosby, 545 U. S. 524 (2005). Neither move
is availing.
1
Highlighting the BOP's role in compassionate release and
the fact that prison offcials can observe things like “ad-
vanced age,” “safety risk,” and “illness,” the majority con-
tends that Congress's centering of the BOP “refects the
statute's focus on a defendant's personal circumstances.”
Ante, at 425. But the majority cannot deny that Congress
amended § 3582(c)(1)(A) due to its concern that the BOP was
mismanaging compassionate-release motions. See supra, at
440–441. The majority's reliance on the BOP's “institutional
expertise,” ante, at 425, to interpret a statutory amendment
aimed at reducing the BOP's involvement is, at best,
counterintuitive.
Recall that Congress amended the compassionate-release
provision as part of the First Step Act—legislation that was
broadly aimed at providing district courts with discretion to
alleviate what many had come to believe were unduly harsh
criminal sentences. See Concepcion v. United States, 597
U. S. 481, 486 (2022). Pointing back to the original, pre-
First Step Act scope of § 3582(c)(1)(A) does not account for
Congress's subsequent conclusion that BOP was applying the
compassionate-release provision too narrowly. And when it
invited district courts to consider § 3582(c)(1)(A) motions
fled directly by defendants, Congress did not say, or even
suggest, that a sentence reduction under this provision is
only available based on the kinds of factors BOP might raise.
Fernandez's concession that the First Step Act “did not
change the substantive standard applicable to” § 3582(c)
(1)(A), ante, at 425 (citing Tr. of Oral Arg. 9–12), is not to
the contrary. That observation merely states the obvious:
that the meaning of “extraordinary and compelling reasons”
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Jackson, J., dissenting
has always been expansive, leading Congress to conclude
that the BOP had been misinterpreting “extraordinary and
compelling” all along. See Letter from 12 U. S. Senators 3
(expressing “dee[p] concer[n]” about the BOP's underutiliza-
tion of compassionate release); § 603(b), 132 Stat. 5239 (titling
the First Step Act's amendment to § 3582(c)(1)(A) “Increas-
ing the Use and Transparency of Compassionate Release”).
Fernandez seeks to redeem the statute's meaning, not to
change it.
The majority also tells only half the story when it declares
that, “[f]or decades, the Sentencing Commission has tied the
availability of compassionate release to a defendant's per-
sonal circumstances.” Ante, at 426. To be sure, the agency
has always identifed certain personal characteristics (such
as “ `a serious physical or medical condition' ”). But it has
also included a catchall category for any circumstances de-
termined to be “ `extraordinary and compelling.' ” United
States Sentencing Commission, Guidelines Manual Supp. to
App. C, Amdt. 683 (Nov. 2008) (USSG) (effective Nov. 2006);
id., Amdt. 698 (effective Nov. 2007); id., Amdt. 799
(Nov. 2016); see USSG § 1B1.13(b)(5) (Nov. 2025) (provid-
ing that “any other circumstance or combination of cir-
cumstances that . . . are similar in gravity” to the specif-
cally enumerated ones may constitute “extraordinary and
compelling” reasons for a sentence reduction (emphasis
added)).
The takeaway from all this is not, as the majority sug-
gests, that compassionate release has always been under-
stood to be limited to certain kinds of factors (i. e., personal
circumstances). See ante, at 424–425. Rather, the statutory
and regulatory history establishes that § 3582(c)(1)(A) pro-
vides for fexibility and, with one exception, imposes no sub-
stantive categorical restrictions on what may constitute a
basis for compassionate release. See § 3582(c)(1)(A); see also
§ 994(t) (noting that “[r]ehabilitation” is not on its own a stat-
utorily recognized reason for compassionate release). That
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Jackson, J., dissenting
view tracks with the language of § 3582(c)(1)(A)—which
vests district courts with broad discretion to determine
whether “extraordinary and compelling reasons” justify a
sentence reduction—as well as the unmistakable safety-
valve aims of the statute.
2
The majority's reliance on the habeas-channeling analysis
in Preiser and Gonzalez is equally misplaced.
Start with Preiser. In that case, we considered a 42
U. S. C. § 1983 claim brought by state prisoners who asserted
the unconstitutional deprivation of “good-conduct-time cred-
its” that would have shortened their sentences. 411 U. S.,
at 476. The prisoners sought “injunctive relief to compel
restoration of the credits, which in each case would result in
their immediate release from confnement.” Ibid. We held
that the state prisoners could not seek such an injunction
under § 1983 and instead had to proceed under 28 U. S. C.
§ 2254, the habeas statute for state prisoners. Id., at 490,
500. In so holding, we explained that § 1983 is a “general”
statute that broadly guarantees equitable and legal remedies
for the deprivation of any federal right. Id., at 489. Its
breadth causes it to bump up against § 2254, which is “spe-
cifc” in that it was “explicitly and historically designed to
provide the means for a state prisoner to attack the validity
of his confnement” and only after the “exhaustion of ade-
quate state remedies.” Ibid. We feared that privileging
the general would cause it to drown the specifc. We thus
reasoned that Congress's “specifc determination” that “ha-
beas corpus is the appropriate remedy for state prisoners
attacking the validity of the fact or length of their confne-
ment” must “override the general terms of § 1983.” Id.,
at 490.
Unlike § 1983, § 3582(c)(1)(A) is not a “general” statute that
protects all rights and provides for all sorts of civil remedies.
Instead, it creates a specifc mechanism for granting a sen-
tence reduction in the criminal context. Preiser's reasoning
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Jackson, J., dissenting
is therefore inapposite, as it would be odd to conclude that
Congress intended a statute specifcally authorizing release
from prison to impliedly limit another statute that authorizes
the same. The better inference is that Congress meant for
these two statutes to exist side by side and not to the exclu-
sion of one another.2
Gonzalez is equally inapposite. There, we held that pris-
oners cannot use motions for “relief from a fnal judgment”
under Federal Rule of Civil Procedure 60(b) to circumvent
the statutory limitations on second-or-successive habeas ap-
plications. 545 U. S., at 528. But Rule 60(b), like § 1983, is
a general mechanism for civil relief. It allows federal courts
to “relieve a party . . . from a fnal judgment” for “any . . .
reason that justifes relief.” Fed. Rule Civ. Proc. 60(b)(6).
It is a far cry from § 3582(c)(1)(A), which, like § 2255, specif-
cally authorizes release from prison. Just like Preiser, then,
Gonzalez's interpretation of a general civil provision has
nothing to say about § 3582(c)(1)(A)'s specifc relief scheme
and whether Congress meant for it to be cancelled out by an
implicit habeas-review bar.
Instead of acknowledging the poor ft of Preiser and Gon-
zalez, the majority doubles down, insisting that these cases
stand for “an anticircumvention principle.” Ante, at 421, n. 3.
That might well be a common thread. But the majority does
2 Preiser also refected basic principles that have no relevance here—
namely, “[t]he strong considerations of comity that require giving a state
court system that has convicted a defendant the frst opportunity to cor-
rect its own errors.” 411 U. S., at 492. Allowing the state prisoners in
Preiser to proceed under 42 U. S. C. § 1983—which, unlike 28 U. S. C.
§ 2254, requires no exhaustion of state remedies—would have resulted in
“unnecessary friction between the federal and state court systems.” Id.,
at 490. But federal (not state) prisoners bring compassionate-release mo-
tions. And those motions are usually heard by the same federal courts
that oversaw their convictions, imposed their sentences, and considered
any § 2255 applications. Preiser's concern with creating friction between
two autonomous judicial systems does not arise in the compassionate-re-
lease context.
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not explain why the anticircumvention principle applies to
§ 3582(c)(1)(A)—a statute that, unlike § 1983 or Rule 60(b),
specifcally authorizes the release of prisoners under given
circumstances. For the anticircumvention principle to be
apposite, one (specifc) statutory directive must be poten-
tially undercut by another (broader) provision. But that
does not happen here: Both § 2255 and § 3582(c)(1)(A) estab-
lish specifc circumstances under which the release of a pris-
oner is authorized. So the circumvention concern is not im-
plicated on these facts.
Put differently, the majority assumes that compassionate
release operates as an end-run around habeas restrictions.
But there is nothing in either statute that corroborates the
majority's intuition that habeas restrictions take primacy
over the “extraordinary and compelling reasons” justifying
compassionate release.
C
Perhaps even more troubling than the lack of support for
today's holding is the uncertainty this case will create mov-
ing forward. That uncertainty results, in part, from the ma-
jority's backwards reasoning: It starts with the premise that
Fernandez is functionally attempting to use § 3582(c)(1)(A) to
attack his conviction collaterally and, from there, concludes
that § 2255 must prevent this sort of end-run around the
strict process for habeas relief. But that reasoning rests on
the unfounded assumption that Fernandez is essentially
seeking to have his conviction vacated rather than his sen-
tence shortened. Those are two completely different asks.
And the majority's reasoning also merely assumes that they
are incompatible.
Worse still, on its way to announcing that “[a] prisoner
who collaterally attacks the validity of his conviction must
proceed through” habeas only, the majority fails to defne
with any precision what it means for a prisoner to “collater-
ally attac[k] the validity of his conviction.” Ante, at 415.
Its inability to do so is understandable, since delineating the
bounds of such “collateral attacks” is notoriously diffcult.
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Jackson, J., dissenting
Cf. W. Baude, J. Goldsmith, J. Manning, J. Pfander, & A.
Tyler, Hart and Wechsler's The Federal Courts and the Fed-
eral System 1687 (8th ed. 2025) (Hart & Wechsler) (discuss-
ing the diffculty of determining when, under the Preiser line
of cases, a successful § 1983 action necessarily implies “the
invalidity of the plaintiff's conviction”).3
This case illustrates why the new line the majority draws
is a fuzzy one. The District Court did not question the le-
gality of the jury's verdict or Fernandez's conviction. See
2022 WL 17039059, *4 (SDNY, Nov. 17, 2022). To the con-
trary, it found that despite the lawfulness of Fernandez's con-
viction, its lingering “concer[n]” as to his guilt was an “ex-
traordinary and compelling” reason for a sentence reduction.
Ibid. A prisoner who proceeds through § 2255, however,
must show that his sentence was unlawful—specifcally, that
it was “imposed in violation of the Constitution or laws of
the United States.” § 2255(a). That is something Fernan-
dez cannot defnitively do, given this Court's expressed
doubts about whether “a freestanding claim of actual inno-
cence” suffces to establish the unlawfulness of a sentence.
McQuiggin v. Perkins, 569 U. S. 383, 392 (2013).
So, how, exactly, does the District Court's “extraordinary
and compelling” fnding qualify as a collateral attack on Fer-
nandez's conviction for § 2255 purposes, as the majority
3 Seeming to acknowledge the diffculty of defning a “collateral attack”
under Preiser, the majority shoos away this point by maintaining that
such problems arise only when a prisoner seeks “relief other than a release
from custody.” Ante, at 428–429, n. 6. But context matters; before
today, this Court had not applied the Preiser line of cases to a statute that
specifcally authorizes release from custody. Now that the majority has
extended Preiser to such a statute, hard questions are sure to follow, in-
cluding one of the questions at the core of this case: Why should Preiser's
logic apply to a prisoner who seeks compassionate release on a basis that
is not cognizable in habeas? Cf. Hart & Wechsler 1689 (questioning
whether a state prisoner who brings a constitutional claim under § 1983
can escape Preiser and its progeny “by arguing that a victory in a § 1983
action will not invalidate the prior conviction precisely because no court
has jurisdiction” to entertain his claim under § 2254 (emphasis added)).
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Jackson, J., dissenting
maintains? See ante, at 427. The District Court did not
fnd, for instance, that Fernandez should be released from
prison because his sentence or conviction was unconstitu-
tional or otherwise unlawful. Rather, the District Court
considered whether Fernandez might actually be innocent—
something we have never recognized as a potential ground
for habeas relief. See McQuiggen, 569 U. S., at 392. It is
hard to see why this consideration actually creates the end-
run around habeas the majority fears.4
One could easily imagine similar diffculties arising in
other cases. Consider, for instance, a federal prisoner who
fles a § 2255 motion arguing that his conviction and sentence
are unconstitutional because a chronic mental illness ren-
dered him incompetent to plead guilty or stand trial. In
resolving the § 2255 motion, the district court might reject
as unreliable the evidence supporting the severity of the
prisoner's condition. See, e. g., Cohn v. United States, 2023
WL 4670839, *13 (NDNY, July 10, 2023) (rejecting § 2255 mo-
tion on these grounds). Under the majority's rule, would
that prisoner be precluded from citing his mental condition
in a subsequent § 3582(c)(1)(A) motion? Maybe. But that
would certainly be an odd result, given the majority's sug-
gestion that chronic illnesses are “heartland `extraordinary
and compelling reasons' that might warrant an early release
from prison.” Ante, at 426.
4 In response, the majority offers only the ipse dixit that “[t]here is an
obvious distinction between a prisoner who asserts that he should not
have been convicted in the frst place and one who asserts that his present
circumstances warrant an exercise of compassion.” Ante, at 428–429, n. 6.
With the right framing, this “obvious” distinction falls apart: What about
the prisoner who seeks compassion for the present circumstance of being
incarcerated for a crime he did not commit? In any event, Fernandez is
not arguing (and the District Court did not conclude) that he never should
have been convicted. See 2022 WL 17039059, *4 (SDNY, Nov. 17, 2022)
(observing that “jury verdicts, despite being legal, also may be unjust”
and citing this observation as “the basis of [its] fnding that . . . Fernandez
ha[d] shown extraordinary and compelling circumstances for his release”).

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Jackson, J., dissenting
Thus, the line between a proper compassionate-release
claim and a proper habeas claim could be diffcult to draw
moving forward. The majority ignores this problem rather
than taking it as a clue that the habeas-based limitation it
favors is an ill ft for the distinct compassionate-release
evaluation.
III
For the reasons I have given, I think the majority is wrong
to hold, as a categorical matter, that conviction-related con-
cerns a prisoner may raise under § 2255 can never be grounds
for granting a motion under § 3582(c)(1)(A). In my view, all
facts and circumstances are eligible to be considered as
grounds for granting a compassionate-release motion.
Other than the rehabilitation restriction, see 28 U. S. C.
§ 994(t), the only statutory limit on the District Court's dis-
cretion is one of degree. So, if the proffered facts and cir-
cumstances (of whatever type) provide an “extraordinary and
compelling reason” to reduce the prisoner's sentence (alone
or in combination), the District Court may grant compassion-
ate release.
I do not take a position as to whether Fernandez's case
meets that threshold. The District Court thought so—it
laid out the evidentiary gaps that caused it to have serious
doubts about whether Fernandez was involved in the under-
lying crime at all. See 2022 WL 17039059, *4.5 Also nota-
5 In a nutshell, the District Court expressed concern that Patrick
Darge—Fernandez's codefendant and the primary witness against him—
falsely implicated Fernandez as his “back-up” shooter. See 2022 WL
17039059, *4. The District Court emphasized that Darge fed to the Dom-
inican Republic with his brother immediately after the shooting, while
Fernandez remained in the United States, living with his family and accru-
ing no criminal record. Ibid. This suggested to the District Court that
Darge may have lied to protect his brother (perhaps the true “back-up”)
and to secure a deal for himself. Ibid. The District Court observed sev-
eral facts supporting this conclusion, including that Darge had lied to the
Government about the shooting previously and that his testimony was
inconsistent with the ballistics evidence. Ibid.
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452 FERNANDEZ v. UNITED STATES
Jackson, J., dissenting
ble, the District Court based its § 3582(c)(1)(A) ruling on both
its “disquiet” about Fernandez's potential innocence and
the signifcant disparity between Fernandez's sentence and
his codefendants' sentences. Ibid. But due to the categori-
cal rule the Second Circuit employed, that court did not ad-
dress whether the District Court erred in concluding that
§ 3582(c)(1)(A)'s “extraordinary and compelling reasons”
threshold was satisfed on these facts. See 104 F. 4th 420,
429–433 (2024). I would vacate the judgment below and re-
mand for the Second Circuit to make that assessment in the
frst instance.6
* * *
The Court's holding in this case refects an unfortunate
misunderstanding of the safety-valve mechanism Congress
created in 1984 and broadened in 2018. Congress designed
compassionate release as a tool for preserving a modicum of
mercy in an otherwise harsh sentencing system. And noth-
ing about the text or history of the compassionate-release
6 Recognizing the lack of textual support for the majority's habeas-based
rule, two Justices would affrm the Second Circuit's ruling on a different
ground. In their view, “[a] motion for compassionate release cannot jus-
tify a reduced sentence if it relies solely on facts a court already considered
in imposing the initial sentence, rather than any changed circumstances
that developed after sentencing.” Ante, at 431 (Sotomayor, J., concur-
ring in judgment). It is perhaps true that, in many (if not most) cases, a
compassionate-release motion rehashing old arguments and evidence will
not satisfy the “extraordinary and compelling” standard. But I see no
basis in § 3582(c)(1)(A) for categorically barring relief in all cases where
the defendant fails to identify changed circumstances. See Part I–A,
supra (explaining that the words “extraordinary and compelling” speak to
degree, not type).
In any event, the Second Circuit did not rely on any such changed-
circumstances rule in reversing the District Court's grant of compassion-
ate release, nor did the parties address it in their briefng. As such, even
if the changed-circumstances rule were correct, the proper course would
be to vacate the decision below for the Second Circuit to apply the rule in
the frst instance. See Cutter v. Wilkinson, 544 U. S. 709, 718, n. 7 (2005)
(“[W]e are a court of review, not of frst view”).
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Jackson, J., dissenting
provision suggests that Congress meant for this discretion-
ary second-look opportunity to be cabined in the way the
majority suggests. In other words, Congress gave prison-
ers an equitable “out” for the extraordinary and compelling
circumstance in which they might otherwise be stuck serving
an unjust sentence. Ironically, then, the escape hatch the
majority decries is actually § 3582(c)(1)(A)'s core mission.
Deploying its own concerns about habeas end-runs, the
majority misses all this; it now drastically limits the avail-
ability of the compassionate-release tool Congress crafted.
And it does so without adequately identifying any true con-
fict with § 2255. The majority's atextual and unsupported
limitation on a district court's sentencing discretion is an un-
necessary rewriting of the statute Congress wrote and an
unwarranted revision of the compassionate-release scheme
Congress intended to establish.
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Reporter’s Note
The attached opinion has been revised to refect the usual publication
and citation style of the United States Reports. The revised pagination
makes available the offcial United States Reports citation in advance of
publication. The syllabus has been prepared by the Reporter of Decisions
for the convenience of the reader and constitutes no part of the opinion of
the Court. A list of counsel who argued or fled briefs in this case, and
who were members of the bar of this Court at the time this case was
argued, has been inserted following the syllabus. Other revisions may
include adjustments to formatting, captions, citation form, and any errant
punctuation. The following additional edits were made:
None

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