Fernandez v. United States

1
(Slip Opinion) OCTOBER TERM, 2025
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES
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 fired 14 rounds and
killed both victims. Fernandez’s alleged co-conspirator, Patrick Darge,
testified against Fernandez at trial. The jury convicted Fernandez of
murder for hire and a firearms offense, and the District Court imposed
two consecutive life sentences.
Fernandez pursued multiple avenues of relief. He first asked the
District Court to reconsider, alleging Brady violations related to the
Government’s failure to disclose that another alleged co-conspirator,
Luis Rivera, had denied driving the getaway car. The District Court
reviewed the Government’s notes from interviewing Rivera and con-
cluded 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 affirmed the conviction and sentence,
rejecting both the Brady claim and Fernandez’s insufficiency-of-evi-
dence argument. It held that a reasonable jury could credit Darge’s
testimony and that the evidence was sufficient to support conviction.
Fernandez then twice moved for postconviction relief under 28 U. S. C.
§2255. The first motion, arguing actual innocence based on witness
credibility, was described by the Second Circuit as “plainly meritless.”
The second succeeded only in vacating his firearms conviction based
on United States v. Davis, 588 U. S. 445, thus leaving in place Fernan-
dez’s murder-for-hire conviction. In the order vacating the firearms
conviction, the District Judge speculated that the Government had of-
fered Rivera a lenient plea deal because it “kn[ew] something” incon-
sistent with Darge’s testimony, and pointedly noted that if

2 FERNANDEZ v. UNITED STATES
Syllabus
Fernandez’s life sentence on the murder-for-hire charge “were to be
commuted, or held unlawful, [Fernandez] would be released immedi-
ately.” 569 F. Supp. 3d 169, 174, n. 4, 179.
Fernandez finally filed 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
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. 5–17.
(a) Section 2255 governs collateral attacks on federal convictions
and imposes tight procedural constraints, including: a 1-year statute
of limitations, §2255(f); a general rule that prisoners get only one shot
at collateral relief with narrow exceptions, §§2255(h)(1)–(2); a bar on
relitigating claims already raised and rejected on direct review, see
Kaufman v. United States, 394 U. S. 217, 227, n. 8; and procedural de-
fault rules requiring demonstration of “‘cause’” and “‘prejudice’” or ac-
tual innocence for claims not raised on direct review, Bousley v. United
States, 523 U. S. 614, 622. This case arises because after Fernandez
lost a challenge to his conviction under §2255, he filed a motion pre-
senting similar arguments under 18 U. S. C. §3582, which permits
prisoners to seek compassionate release from prison by showing “ex-
traordinary and compelling reasons” warrant early release. Unlike the
procedural constraints on §2255 claims, the sole procedural require-
ment imposed by §3582 is that the prisoner must first present his re-
quest 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 specific 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 Office 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 confine-
ment” “must override the general terms of §1983.” 411 U. S., at 490.

3 Cite as: 608 U. S. ___ (2026)
Syllabus
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,
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 benefit of his
approach. His strategy would enable prisoners to bypass §2255 by
challenging convictions repeatedly, for years after they became final,
and regardless whether the issues had already been raised or decided
in prior proceedings.
The text and structure of §3582 confirm that the invalidity of a con-
viction is not among the “extraordinary and compelling reasons” justi-
fying 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 nec-
essarily 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 spe-
cial protection to defendants with “terminal illness,” §3582(d); ex-
pressly identifies that relief is available for elderly prisoners who have
served lengthy sentences and are not dangerous, §3582(c)(1)(A)(ii); and
has permitted the Sentencing Commission to treat rehabilitation as a
relevant consideration, 28 U. S. C. §994(t). The role of the Bureau of
Prisons reflects the statute’s focus on a defendant’s personal circum-
stances 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 “compel-
ling” argument that his conviction was wrongful. Regulatory history
points the same way. For decades, the Sentencing Commission has
tied the availability of compassionate 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]” compas-
sionate release. Pp. 5–13.
(b) Fernandez’s argument that §2255 and §3582 offer different forms
of relief does not help him. The difference in relief highlights the

4 FERNANDEZ v. UNITED STATES
Syllabus
mismatch 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 fitting remedy is to vacate it, as §2255 allows.
Whether a prisoner’s request for relief serves as a challenge to a con-
viction often 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 flawed. This case demon-
strates 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 con-
stitutional violation—fails. No court has concluded Fernandez was ac-
tually innocent. In any event, a prisoner asserting actual innocence
“challenge[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 postconviction statutes. Pp. 13–17.
104 F. 4th 420, affirmed.
B
ARRETT, J., delivered the opinion of the Court, in which ROBERTS,
C. J., and THOMAS, ALITO, GORSUCH, and KAVANAUGH, JJ., joined.
SOTOMAYOR, J., filed an opinion concurring in the judgment, in which
K
AGAN, J., joined. JACKSON, J., filed a dissenting opinion.

_________________
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1 Cite as: 608 U. S. ____ (2026)
Opinion of the Court
NOTICE: This opinion is subject to formal revision before publication in the
United States Reports. Readers are requested to notify the Reporter of
Decisions, Supreme Court of the United States, Washington, D. C. 20543,
pio@supremecourt.gov, of any typographical or other formal errors.
SUPREME COURT OF THE UNITED STATES
No. 24–556
JOE FERNANDEZ, PETITIONER v. UNITED STATES
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF
APPEALS FOR THE SECOND CIRCUIT
[May 28, 2026]
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 infirmity. 18 U. S. C. §3582(c)(1)(A). Petitioner Joe
Fernandez 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 col-
laterally 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 assas-
sination 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 fired 14
rounds, killing both victims.
Fernandez’s cousin and alleged co-conspirator, Patrick
Darge, testified against him at trial. To discredit Darge,
Fernandez’s counsel argued that Darge was framing Fer-
nandez to protect the real second shooter, Darge’s brother.
Unconvinced, the jury convicted Fernandez of murder for

2 FERNANDEZ v. UNITED STATES
Opinion of the Court
hire and a firearms offense. See 18 U. S. C. §§924(j), 1958.
The District Court then imposed two consecutive life sen-
tences.
Fernandez asked the District Court to reconsider, alleg-
ing that the prosecution had violated Brady v. Maryland,
373 U. S. 83 (1963). He pressed that argument several
times, first in a motion to vacate the verdict, then in a mo-
tion for new trial, and again in a motion for rehearing. Ac-
cording to Fernandez, the Government should have dis-
closed that another alleged co-conspirator, Luis Rivera, had
denied driving the getaway car. To determine whether Ri-
vera had in fact denied his involvement, the District Court
reviewed the Government’s notes from Rivera’s interview;
it concluded that they “d[id] not contain any relevant infor-
mation.” 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 “al-
low[ed] Rivera to plead to a lesser narcotics offense and
[had] dismiss[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 engaged in similar wrongdoing. Ibid.
Fernandez appealed, and the Second Circuit affirmed 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 reflect Rivera’s unequivocal de-
nial 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. Fer-
nandez also argued that insufficient evidence supported his
conviction: He insisted that Darge’s testimony was not cred-
ible and highlighted the Government’s choice not to charge
Rivera as a co-conspirator in the murder-for-hire plot,

3 Cite as: 608 U. S. ____ (2026)
Opinion of the Court
which he considered indicative of the weakness of the Gov-
ernment’s case. But the court rejected the insufficiency
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 sufficient to
support Fernandez’s conviction.
Fernandez persisted. He twice moved for postconviction
relief under 28 U. S. C. §2255. The first time, Fernandez
argued (among other things) that he was actually innocent
because the testimony against him was not credible. He
said that “[e]ven the Government did not fully believe Pat-
rick Darge,” as shown by the Government’s decision not to
charge Rivera with murder for hire. Reply Brief in No. 18–
06 (CA2), pp. 8–9, n. 2. The Second Circuit described this
argument as “plainly meritless,” concluding that “[t]he jury
was entitled to credit the witnesses who testified that Fer-
nandez committed the crimes with which he was charged.”
Fernandez v. United States, 757 Fed. Appx. 52, 55–56
(2018). The second collateral challenge succeeded. The Dis-
trict Court set aside Fernandez’s conviction for a firearms
offense after United States v. Davis, 588 U. S. 445 (2019),
held that 18 U. S. C. §924(c)(3)’s residual clause is uncon-
stitutionally 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 firearms conviction, the judge
speculated that the Government had offered Rivera such a
lenient plea deal because it “kn[ew] something” incon-
sistent 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 Pat-
rick Darge’s brother . . . was the second shooter, and that
Patrick Darge testified to cover that up.” Ibid. Notably, the

4 FERNANDEZ v. UNITED STATES
Opinion of the Court
Second Circuit had already rejected this argument twice,
and Fernandez had not briefed it again before the District
Court. But the judge brought it up anyway, pointedly not-
ing that if Fernandez’s life sentence on the murder-for-hire
charge “were to be commuted, or held unlawful, [Fernan-
dez] would be released immediately.” Id., at 179.
Fernandez took the hint. Within two weeks, he filed 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
uncorroborated by forensic evidence; moreover, his identifi-
cation of Rivera as the getaway driver was inconsistent
with a later statement made by Rivera himself. The Gov-
ernment 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 “sacrifice[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] finding that Petitioner
Joe Fernandez has shown extraordinary and compelling
circumstances for his release.” Ibid.
1
——————
1
The District Court also granted compassionate release based on the
sentencing “disparity between Fernandez’[s] life sentence and the

5 Cite as: 608 U. S. ____ (2026)
Opinion of the Court
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 defendant to ‘evade the collateral review structure’ of sec-
tion 2255.” 104 F. 4th, at 430 (alteration omitted).
While seven other Circuits have reached the same con-
clusion, two have taken the other side.
2
We granted certio-
rari 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 typ-
ically 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
——————
sentences 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.
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).

6 FERNANDEZ v. UNITED STATES
Opinion of the Court
direct 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 enti-
tles him to relief. Section 2255’s companion statute, 28
U. S. C. §2254, imposes similar constraints on state prison-
ers.
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 stat-
ute, 18 U. S. C. §3582, which permits prisoners to seek com-
passionate release from prison. In contrast to §2255’s
reticulated scheme, §3582 imposes a single procedural re-
quirement: A prisoner must first present his request for re-
lease to the Bureau of Prisons. §3582(c)(1)(A). A motion
may then be filed in district court, where the prisoner (or
the Bureau, acting on his behalf ) must show that “extraor-
dinary and compelling reasons” warrant his early release
from confinement. §3582(c)(1)(A)(i).
This is not the first time we have addressed the relation-
ship between the habeas statutes and other kinds of pris-
oner 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
appropriate remedy for state prisoners attacking the valid-
ity of the fact or length of their confinement, and that spe-
cific determination 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 specific federal
habeas corpus statute”—in that case §2254—which was
“explicitly and historically designed to provide the means

7 Cite as: 608 U. S. ____ (2026)
Opinion of the Court
for a state prisoner to attack the validity of his confine-
ment.” Id., at 489. A contrary result would allow prisoners
to evade §2254’s requirements, and so would “wholly frus-
trate explicit congressional intent.” Ibid. That is why
“§1983 must be read in harmony with the habeas statute.”
District Attorney’s Office for Third Judicial Dist. v. Os-
borne, 557 U. S. 52, 66 (2009).
Gonzalez v. Crosby, 545 U. S. 524 (2005), flows in the
same vein. There, we held that prisoners may not use Fed-
eral Rule of Civil Procedure 60(b) to argue that a denial of
habeas relief was wrong on the merits and warrants reo-
pening. The language of Rule 60(b) is expansive, permit-
ting courts to reopen a final judgment whenever a movant
shows “any . . . reason that justifies 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) motion to make merits arguments would still col-
lide with §2254. It would permit movants to “circumvent”
the strict statutory habeas standards, including “that a suc-
cessive habeas petition be precertified by the court of ap-
peals.” 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 (quot-
ing 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

8 FERNANDEZ v. UNITED STATES
Opinion of the Court
through a compassionate release motion circumvents the
exacting requirements of §2255.
3
Indeed, Fernandez candidly admits that avoiding §2255’s
procedural and substantive requirements is the benefit of
his approach. As for procedure: Fernandez asserted at oral
argument 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
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
——————
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 “specific.” Post, at 14–16 (opinion of J
ACKSON, J.). But
Preiser and Gonzalez do not lay the relevant statutes side-by-side to de-
termine 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.) In-
stead, both cases apply an anticircumvention principle: They ask
whether it would “impermissibly circumvent” the specific design of the
habeas statute to permit prisoners to challenge the legality of their con-
finement through a statute whose literal language might otherwise ap-
ply. Gonzalez, 545 U. S., at 532; see also Preiser, 411 U. S., at 489. We
undertake the same inquiry here.

9 Cite as: 608 U. S. ____ (2026)
Opinion of the Court
to offer deserving prisoners relief from the rigors of §2255.
Post, at 21 (opinion of J
ACKSON, 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 final, 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 repack-
aged 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 Of-
fice, 557 U. S., at 66. Congress made compassionate release
available only when “extraordinary and compelling rea-
sons” justify it. §3582(c)(1)(A)(i). That is a demanding
standard. And as we did with §1983 in Preiser and
Rule 60(b) in Gonzalez, we interpret §3582 against the
backdrop of the detailed process that Congress “explicitly
and historically designed” for “attack[ing] the validity of [a
prisoner’s] confinement.” 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
compassionate release.
While Congress has not defined 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 lit-
tle or no precedent.” Webster’s Third New International
Dictionary 807 (1976); see 5 Oxford English Dictionary 614
(2d ed. 1989) (“[o]ut of the usual or regular course or order”).

10 FERNANDEZ v. UNITED STATES
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“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 Dic-
tionary, at 600 (“irresistible; demanding attention, re-
spect”). 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 sen-
tence. 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
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 compelling reason to reduce the sentences of prisoners
who fall short.
——————
4
The dissent acknowledges that it is “obviously true” that context in-
forms which reasons count as “compelling.” Post, at 4. The concurrence
agrees, for it proposes another context-based limit: that only “changed
circumstances” qualify as reasons warranting sentencing reduction.
Post, at 1–2 (S
OTOMAYOR, J., concurring in judgment). Given that the
concurrence embraces a limit that appears nowhere in the text, it is hard
to see how the concurrence can resist our interpretation on the ground
that it is “atextual.” Post, at 1.

11 Cite as: 608 U. S. ____ (2026)
Opinion of the Court
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 prepar-
ing those compassionate 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
identifies one situation in which a sentencing 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 Bureau of Prisons de-
termines “that the defendant is not a danger to the safety
of any other person or the community.” §3582(c)(1)(A)(ii).
And in another statute that references §3582(c)(1)(A), Con-
gress has permitted the Sentencing Commission to treat a
defendant’s rehabilitation as a relevant consideration in
granting compassionate release. 28 U. S. C. §994(t).
The role of the Bureau of Prisons reflects the statute’s fo-
cus on a defendant’s personal circumstances—his advanced
age, safety risk, illness, rehabilitation, and the like. The
Bureau evaluates compassionate release motions in the
first instance. Until 2018, a district court could reduce a
sentence only “‘upon motion of the Director of the Bureau
of Prisons.’” Sentencing Reform Act of 1984, 98 Stat. 1998–
1999. After the First Step Act, prisoners may file their own
compassionate release motions, but only if the Bureau de-
clines or fails to respond to a prisoner’s request that the Di-
rector file on his behalf. 132 Stat. 5239. Fernandez agrees
that this procedural shift in the Bureau’s role—from

12 FERNANDEZ v. UNITED STATES
Opinion of the Court
exclusive filer to initial evaluator—did not change the sub-
stantive standard applicable to compassionate release mo-
tions. 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 relat-
ing to their “safekeeping,” “care,” “subsistence,” “protec-
tion,” “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.
Washington, 466 U. S. 668 (1984)? Supra, at 8. Congress’s
decision to route compassionate release motions through
the Bureau strongly suggests that the “extraordinary 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
statements about when compassionate release is war-
ranted, 28 U. S. C. §994(t), and these policy statements
shape whether courts may grant compassionate release mo-
tions, 18 U. S. C. §3582(c)(1)(A). For decades, the Sentenc-
ing Commission has tied the availability of compassionate
release to a defendant’s personal circumstances. See
United States Sentencing Commission, Guidelines Manual

13 Cite as: 608 U. S. ____ (2026)
Opinion of the Court
App. C, Amdt. 698 (Nov. 2007) (USSG) (listing “‘extraordi-
nary and compelling reasons’” to include “‘terminal ill-
ness,’” “‘a permanent physical or medical condition,’”
“ ‘[t]he death or incapacitation of the defendant’s only fam-
ily members capable of caring for the defendant’s minor
child,’” or “‘other’” reasons as determined by the Director
of the Bureau of Prisons). While the Sentencing Commis-
sion 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 qualifies as an “ex-
traordinary and compelling reaso[n] warrant[ing]” compas-
sionate 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 re-
lease from prison—age, illness, a child left with no guard-
ian—bear no resemblance to the grounds for relief under
§2255. Fernandez 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
——————
5
In 2023, the Sentencing Commission added a new category to the list
of “extraordinary and compelling” reasons: “ ‘Unusually Long Sen-
tence[s].’ ” USSG Supp. to App. C, Amdt. 814 (Nov.). That amendment,
while not relevant here, exceeds the Commission’s authority. Rutherford
v. United States, ___ U. S. ___, ___–___ (2026) (slip op., at 15–16).

14 FERNANDEZ v. UNITED STATES
Opinion of the Court
distinction, he says, means that he is not circumventing
§2255, but rather proceeding on an entirely different track.
See also post, at 11 (J
ACKSON, 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 infirm 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
fitting remedy is to vacate it, as §2255 allows. That §3582
does not offer this remedy is evidence that it is not a suita-
ble 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-
finement” and “seeks either immediate release from that
confinement or the shortening of its duration,” his claim be-
longs 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 argu-
ments presented. See, e.g., Gonzalez, 545 U. S., at 531, 533
(holding that only some arguments presented in a Rule
60(b) motion would improperly infringe on §2254). When a
prisoner moves for compassionate release based on a termi-
nal illness, his motion does not suggest that his conviction
is invalid. But if a prisoner moves for relief because of

15 Cite as: 608 U. S. ____ (2026)
Opinion of the Court
alleged problems with the underlying criminal investiga-
tion or trial, his motion suggests that his conviction is
flawed. That is true here: Fernandez’s motion said he
“would never commit” murder 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 exculpatory” notes from interviewing Ri-
vera; and even argued that Fernandez could sufficiently
show his actual innocence to satisfy Schlup v. Delo, 513
U. S. 298 (1995), which governs certain procedurally de-
faulted habeas claims. See ECF Doc. 248, pp. 7–9, 14. The
District Court then impermissibly treated Fernandez’s
challenge to his conviction as an “extraordinary and com-
pelling reaso[n]” for sentencing reduction. 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 define “what it means
for a prisoner to ‘collaterally attac[k] the validity of his conviction,’” post,
at 17 (alteration in original), and characterizes this limit as unworkable,
post, at 9, 16–19; see also post, at 1 (S
OTOMAYOR, J., concurring in judg-
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 first place and one
who asserts that his present circumstances warrant an exercise of com-
passion. Cf. Gonzalez v. Crosby, 545 U. S. 524, 532 (2005) (requiring dis-
trict courts to distinguish between Rule 60(b) motions that attack “the
substance 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 pro-
ceedings”). Indeed, we routinely require courts to draw much finer dis-
tinctions 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

16 FERNANDEZ v. UNITED STATES
Opinion of the Court
Fernandez offers a backup position: Even if
§3582(c)(1)(A)(i) does not ordinarily allow district courts to
grant compassionate release for reasons that would support
a §2255 motion, he asserts that actual innocence claims are
an exception. He points out that “a factual showing of ac-
tual innocence ‘ha[s] never been held to state a ground for
federal habeas relief absent an independent constitutional
violation.’” Brief for Petitioner 41–42 (quoting Herrera v.
Collins, 506 U. S. 390, 400 (1993)). Thus, he says, such a
claim must be cognizable under §3582; otherwise, a pris-
oner might have nowhere to go. See also post, at 9–10, 17–
18 (J
ACKSON, 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-
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-
fidence in Fernandez’s innocence. 2022 WL 17039059, *4.
So even if an actual innocence claim were cognizable under
§3582, Fernandez would not benefit from it.
In any event, this case gives us no occasion to decide the
antecedent question whether a prisoner may assert a
——————
circumstances of the offense” but not the “‘need for the sentence imposed’
‘to reflect 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 difficult” 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 17 (citing W. Baude, J. Goldsmith,
J. Manning, J. Pfander, & A. Tyler, Hart and Wechsler’s The Federal
Courts and the Federal System 1687 (8th ed. 2025)). But this source
describes the difficulty of determining when relief other than a release
from custody (for example, a damages award) would “necessarily imply
the invalidity of [the plaintiff’s] conviction” within the meaning of Heck
v. Humphrey, 512 U. S. 477, 487 (1994). That issue has no bearing on
today’s case.

17 Cite as: 608 U. S. ____ (2026)
Opinion of the Court
freestanding 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 “chal-
lenge[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. Gon-
zalez, 545 U. S., at 531. And for the reasons we have al-
ready 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, ___ U. S. ___ (2026). Petitioners in both
cases contend that the phrase “extraordinary and compel-
ling reasons” vests courts with broad discretion to grant a
prisoner compassionate release for virtually any reason
whatsoever. We reject these arguments here for the same
reasons we reject them in Rutherford. Id., at ___–___ (slip
op., at 11–15). “While the terms ‘extraordinary’ and ‘com-
pelling’ leave room for judgment, they are not so flexible as
to encompass any consideration.” Id., at ___ (slip op., at 11).
***
The compassionate release provision is not a vehicle for
attacking the validity of a conviction. Accordingly, the judg-
ment of the Court of Appeals for the Second Circuit is af-
firmed.
It is so ordered.

_________________
_________________
1 Cite as: 608 U. S. ____ (2026)
S
OTOMAYOR, J., concurring in judgment
SUPREME COURT OF THE UNITED STATES
No. 24–556
JOE FERNANDEZ, PETITIONER v. UNITED STATES
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF
APPEALS FOR THE SECOND CIRCUIT
[May 28, 2026]
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 finding
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 J
USTICE JACKSON’s
dissenting opinion, the Court’s decision interpreting that
provision 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 distorts and expands the Court’s habeas-channeling
cases, creating an atextual limitation found nowhere in
§3582(c)(1)(A). In doing so, it superimposes a technical, and
likely unworkable, habeas analysis on top of a sentence-
reduction framework that broadly calls for holistic review.
Moreover, the rule adopted today risks shutting out meri-
torious 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 affirmed 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

2 FERNANDEZ v. UNITED STATES
S
OTOMAYOR, J., concurring in judgment
the initial sentence, rather than any changed circum-
stances 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 finality when “extraordinary and compelling reasons”
arise so as to “warrant . . . a reduction” of the sentence im-
posed. 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 first sentenc-
ing’ produc[e] unfairness to the defendant” (citation omit-
ted)). Otherwise, district courts would have indefinite au-
thority to revise sentences already imposed based on
information and arguments that were previously consid-
ered and rejected. Such authority would seriously diminish
the finality 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 1–2, at his
sentencing, see App. 57–62, in a motion to reconsider his
sentence, see ante, at 2–3, and in a postconviction motion
under 28 U. S. C. §2255, even though “[n]o new evidence
had surfaced,” ante, at 3–4. Each effort failed in the trial
court and on appeal. Yet these same arguments finally
found success under §3582(c)(1)(A) based on the District

3 Cite as: 608 U. S. ____ (2026)
S
OTOMAYOR, J., concurring in judgment
Court’s renewed feelings of “‘doub[t]’” and “‘disquiet’”
about the original trial evidence supporting Fernandez’s
jury verdict. Ante, at 4.*
This grant of relief was inappropriate given the absence
of any postsentencing developments, and the Court needed
to go no further to affirm the decision below. Unfortu-
nately, bad facts often make bad law, and so they did today.
Correctly perceiving a problem with the District Court’s
grant of relief, the majority responds with a rule that goes
far beyond both what is needed to resolve this case and,
worse, what the text and relevant precedents can bear. Be-
cause I do not agree with the majority’s reasoning in sup-
port of its decision to affirm the decision below, I concur
only in the judgment of the Court.
——————
*As the majority notes, ante, at 4, n. 1, the District Court also relied
on a sentencing disparity between Fernandez and some of his codefend-
ants in granting relief, but the Second Circuit rejected that separate ba-
sis for relief on grounds unrelated to the question that this Court granted
certiorari to review, 104 F. 4th 420, 428–429 (2024).

_________________
_________________
1 Cite as: 608 U. S. ____ (2026)
J
ACKSON, J., dissenting
SUPREME COURT OF THE UNITED STATES
No. 24–556
JOE FERNANDEZ, PETITIONER v. UNITED STATES
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF
APPEALS FOR THE SECOND CIRCUIT
[May 28, 2026]
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 specified
circumstances. This case is about the scope of that author-
ity. By its terms, the compassionate-release statute is flex-
ible, permitting sentence reductions for “extraordinary and
compelling reasons.” 18 U. S. C. §3582(c)(1)(A)(i). The
breadth of this language is no accident: It reflects Con-
gress’s intent to preserve some of the traditional discretion
afforded to district courts to ensure just treatment of de-
fendants in criminal 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” findings on any reason that “collaterally attacks the
validity” of the prisoner’s conviction. Ante, at 1. Such “at-
tacks,” the majority says, must be brought through motions
for habeas relief under 28 U. S. C. §2255. Ibid. But this
restriction comes of out nowhere—it finds no support in the
statute’s text or history, nor can it be justified by our prec-
edents.
What, then, explains the new categorical rule that the
Court adopts today? The answer appears to be the major-
ity’s intuition that the District Court’s grant of petitioner
Joe Fernandez’s compassionate-release motion qualifies as

2 FERNANDEZ v. UNITED STATES
J
ACKSON, J., dissenting
an abuse of discretion under the circumstances presented
here. That may well be true—but not because of an im-
plicit, 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 affirm, 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]ollat-
eral attacks on federal convictions” are not authorized.
Ante, at 5. It is not clear whether the majority believes, on
the one hand, that conviction-related concerns can never be
sufficiently “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 focused
instead on the statute actually before it, it would have seen
that the compassionate-release provision operates as an in-
dependent 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 un-
derstood, it is clear that the existence of habeas review has
no bearing whatsoever on whether a defendant can seek or
obtain compassionate release.

3 Cite as: 608 U. S. ____ (2026)
J
ACKSON, J., dissenting
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 compas-
sionate-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
habeas-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 “extraordinary” and “compelling” are commonly un-
derstood to relate to a narrow and specific set of circum-
stances defined by degree, not type. See Rutherford v.
United States, ___ U. S. ___, ___ (2026) (S
OTOMAYOR, J., dis-
senting) (slip op., at 7–8). As the majority acknowledges,
“ ‘[e]xtraordinary’ means ‘most unusual,’ ‘far from common,’
and ‘having little or no precedent,’” while “‘compelling’
means ‘tending to convince or convert by or as if by forceful-
ness of evidence.’” Ante, at 9–10 (quoting Webster’s Third
New International Dictionary 463, 807 (1976)). Neither
definition 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 compas-
sionate release, so long as it is both sufficiently unusual and
sufficiently forceful. See Romag Fasteners, Inc. v. Fossil
Group, Inc., 590 U. S. 212, 215 (2020) (observing that this
Court does not “usually read into statutes words that aren’t
there”).

4 FERNANDEZ v. UNITED STATES
J
ACKSON, J., dissenting
The statutory context confirms 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 pol-
icy statements. 18 U. S. C. §3582(c)(1)(A). Second, “[r]eha-
bilitation 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” findings “ ‘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 come-
back. Focusing on the word “compelling,” the majority ob-
serves that what “is compelling in one context is not neces-
sarily so in another”; for example, a 25th wedding
anniversary may be a “compelling” reason to shorten a busi-
ness trip but not a prison sentence. Ante, at 10. While ob-
viously true, that observation tells us nothing relevant. All
agree that personal considerations (e.g., illness and family
hardship) might warrant a sentence reduction under
§3582(c)(1)(A), see ante, at 10–12, yet those considerations,
too, are more or less “compelling” under various circum-
stances. Moreover, as explained in Part II–A, infra, Fer-
nandez’s claim of actual innocence, if meritorious, would be
a compelling reason to reduce his sentence. At the time the
District Court considered his §3582(c)(1)(A) motion, Fer-
nandez had already served 11 years in federal prison for a
crime he says he did not commit. On the “extraordinary
and compelling reasons” scale, his innocence claim is

5 Cite as: 608 U. S. ____ (2026)
J
ACKSON, J., dissenting
lightyears away from reducing a sentence to facilitate cele-
bration of a wedding anniversary.
B
The text alone suffices to dispel the habeas-related limi-
tation myth the majority adopts today. But, as is often true
of statutes, it is not possible to fully understand the com-
passionate-release provision without appreciating its stat-
utory 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 Congress understood §2255 to implicitly limit the
scope of compassionate release, either when it first enacted
§3582(c)(1)(A) in 1984 or when it amended the provision in
2018.
1
Before 1984, “the Federal Government employed in crim-
inal cases a system of indeterminate sentencing.” Mistretta
v. United States, 488 U. S. 361, 363 (1989). Though “[s]tat-
utes specified 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
instead of imprisonment or fine.” 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 flaw in the existing

6 FERNANDEZ v. UNITED STATES
J
ACKSON, J., dissenting
criminal justice system, and makes it clear that the system
is ripe for reform”). The Act’s most prominent reform was
the creation of the U. S. Sentencing Commission, which
Congress tasked with promulgating a new, determinate
system of Sentencing Guidelines. See §217(a), 98 Stat.
2017 (codified 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 ap-
plicable Guidelines range, but only after “find[ing] an ag-
gravating or mitigating factor present that the Commission
did not adequately consider.” 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 discre-
tion would result in unfairly harsh sentences for some pris-
oners. Indeed, despite the uniformity aim of the Guidelines,
lawmakers acknowledged the possibility of an “exceptional
situation 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 Re-
vision Hearings) (statement of Rep. Lungren). Federal
judges similarly warned of “those occasional cases which
cry out for some sort of revision, even though the sentence
——————
1
Today, of course, the Guidelines are no longer binding—though dis-
trict courts must still “consult” and “take them into account when sen-
tencing.” United States v. Booker, 543 U. S. 220, 264 (2005). The Guide-
lines 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 Guidelines on the Government’s motion”).

7 Cite as: 608 U. S. ____ (2026)
J
ACKSON, J., dissenting
on that particular offender has been imposed by a perfectly
conscientious sentencing 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) per-
mitted the Director of the Bureau of Prisons (BOP) to peti-
tion a sentencing court for a reduction in a prisoner’s sen-
tence. §212(a)(2), 98 Stat. 1998–1999. And it authorized a
court to grant such a petition if, “‘after considering the fac-
tors set forth in section 3553(a),’” the court found “‘that ex-
traordinary and compelling reasons’” justified the reduc-
tion and that such a reduction was “‘consistent with
applicable policy statements issued by the Sentencing Com-
mission.’” Ibid.
Significantly 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 pro-
vision of the Sentencing Reform Act). But it never sug-
gested that §3582(c)(1)(A) and §2255 were mutually exclu-
sive, 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 re-
lease hinged on the unavailability of habeas review. In-
stead, it was clear from the start that compassionate re-
lease was a distinct vehicle for addressing potential
inequities with respect to a defendant’s sentence: one spe-
cifically designed to allow for the flexible consideration of
“extraordinary and compelling” circumstances notwith-
standing the restrictions that otherwise made the sentenc-
ing system less discretionary. Id., at 121 (recognizing the
“value” of “assur[ing] the availability of specific review and

8 FERNANDEZ v. UNITED STATES
J
ACKSON, J., dissenting
reduction of a term of imprisonment for ‘extraordinary and
compelling reasons’”).
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 av-
erage of “only 24 inmates” were “released each year through
the BOP’s compassionate release program.” Dept. of Jus-
tice, Office of Inspector General, The Federal Bureau of
Prisons’ Compassionate Release Program 1 (Apr. 2013).
Over time, it became clear that BOP was drastically un-
derutilizing its compassionate-release power, “resulting in
inmates who may [have been] eligible candidates for release
not being considered.” Id., at 11.
Of particular issue was the BOP’s exceedingly narrow in-
terpretation of the statutory phrase “extraordinary and
compelling,” which its Central Office staff had interpreted
as referring only to “terminally ill medical conditions with
a life expectancy of 1 year or less or those who are incapac-
itated 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 Sen-
ators wrote to the Department of Justice and expressed
“dee[p] concer[n] that BOP [was] not fulfilling 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,

9 Cite as: 608 U. S. ____ (2026)
J
ACKSON, J., dissenting
2017) (statement of Sen. Durbin); see 132 Stat. 5194. In a
section entitled “Increasing the Use and Transparency of
Compassionate Release,” the Act amended the compassion-
ate-release provision to allow prisoners to file their own mo-
tions 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 determi-
nate scheme for sentencing. S. Rep. No. 98–225, at 121. It
was not linked to, or limited by, the existence of habeas re-
view in any respect. And that made perfect sense given the
specific role Congress envisioned for compassionate release:
allowing a discretionary sentence modification for a pris-
oner 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
consideration that supposedly “attacks the validity of [a]
conviction” or sentence. Ante, at 1. One glaring flaw with
this analysis is the majority’s failure to clearly establish
when this forbidden circumstance arises; that is, what, ex-
actly, does it mean for a prisoner to collaterally attack his
conviction in the context of a compassionate-release mo-
tion? 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

10 FERNANDEZ v. UNITED STATES
J
ACKSON, J., dissenting
ineffective or that the prosecution withheld exculpatory ev-
idence. Habeas thus provides no avenue for relief. See 28
U. S. C. §2255(a) (authorizing relief for a defendant whose
“sentence 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-re-
lease safety valve would apply. See Code Revision Hear-
ings, 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 suffice. The concern that Fer-
nandez is making such an unjustified innocence claim
seems to be what drives much of the majority’s analysis to-
day. See ante, at 16 (“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 2 (S
OTOMAYOR, 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 concern
and, in the process, adopts an atextual rule that categori-
cally forbids any consideration of potential innocence what-
soever—no matter how extraordinary or compelling—ei-
ther on its own or as part of a mix of other considerations.
That result certainly does not follow from the text.

11 Cite as: 608 U. S. ____ (2026)
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ACKSON, J., dissenting
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 7–9.
That is because the habeas and compassionate-release pro-
visions operate differently. To be sure, both statutes au-
thorize the release of federal prisoners. But, where the stat-
utory 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 convic-
tion. A neighboring subsection explicitly clarifies that com-
passionate release does not disturb the finality of the “judg-
ment of conviction.” §3582(b). Not so with habeas—when
a §2255 applicant successfully challenges the validity of his
conviction, the result is vacatur. See §2255(b) (“If the court
finds . . . that there has been such a denial or infringement
of the constitutional rights of the prisoner as to render the
judgment vulnerable to collateral attack, the court shall va-
cate and set the judgment aside” (emphasis added)).
Put differently, habeas nullifies 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

12 FERNANDEZ v. UNITED STATES
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ACKSON, J., dissenting
the compassionate-release remedy. It gets there in two
ways: first, by overstating the significance of the BOP’s role
in order to bolster the conclusion that “personal circum-
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 officials can observe things like “ad-
vanced age,” “safety risk,” and “illness,” the majority con-
tends that Congress’s centering of the BOP “reflects the
statute’s focus on a defendant’s personal circumstances.”
Ante, at 11. 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 su-
pra, at 8–9. The majority’s reliance on the BOP’s “institu-
tional expertise,” ante, at 12, 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) mo-
tions filed directly by defendants, Congress did not say, or
even suggest, that a sentence reduction under this provi-
sion is only available based on the kinds of factors BOP
might raise.

13 Cite as: 608 U. S. ____ (2026)
J
ACKSON, J., dissenting
Fernandez’s concession that the First Step Act “did not
change the substantive standard applicable to”
§3582(c)(1)(A), ante, at 11–12 (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” has always been expansive, leading Congress to
conclude that the BOP had been misinterpreting “extraor-
dinary and compelling” all along. See Letter from 12 U. S.
Senators 3 (expressing “dee[p] concer[n]” about the BOP’s
underutilization of compassionate release); §603(b), 132
Stat. 5239 (titling the First Step Act’s amendment to
§3582(c)(1)(A) “Increasing 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
personal circumstances.” Ante, at 12. To be sure, the
agency has always identified certain personal characteris-
tics (such as “‘a serious physical or medical condition’”).
But it has also included a catchall category for any circum-
stances determined 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); USSG
Supp. to App. C, Amdt. 799 (Nov. 2016); see USSG
§1B1.13(b)(5) (Nov. 2025) (providing that “any other cir-
cumstance or combination of circumstances that . . . are
similar in gravity” to the specifically 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 11–12. Rather, the statutory
and regulatory history establishes that §3582(c)(1)(A)

14 FERNANDEZ v. UNITED STATES
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ACKSON, J., dissenting
provides for flexibility and, with one exception, imposes no
substantive 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 statutorily recognized reason for compassionate release).
That view tracks with the language of §3582(c)(1)(A)—
which vests district courts with broad discretion to deter-
mine whether “extraordinary and compelling reasons” jus-
tify a sentence reduction—as well as the unmistakable
safety-valve aims of the statute.
2
The majority’s reliance on the habeas-channeling analy-
sis 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 as-
serted the unconstitutional deprivation of “good-conduct-
time credits” 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 confinement.” Ibid.
We held that the state prisoners could not seek such an in-
junction 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 le-
gal remedies for the deprivation of any federal right. Id., at
489. Its breadth causes it to bump up against §2254, which
is “specific” in that it was “explicitly and historically de-
signed to provide the means for a state prisoner to attack
the validity of his confinement” and only after the “exhaus-
tion of adequate state remedies.” Ibid. We feared that priv-
ileging the general would cause it to drown the specific. We
thus reasoned that Congress’s “specific determination” that
“habeas corpus is the appropriate remedy for state prison-
ers attacking the validity of the fact or length of their

15 Cite as: 608 U. S. ____ (2026)
J
ACKSON, J., dissenting
confinement” 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 rem-
edies. Instead, it creates a specific mechanism for granting
a sentence reduction in the criminal context. Preiser’s rea-
soning is therefore inapposite, as it would be odd to con-
clude that Congress intended a statute specifically author-
izing release from prison to impliedly limit another statute
that authorizes the same. The better inference is that Con-
gress meant for these two statutes to exist side by side and
not to the exclusion of one another.
2
Gonzalez is equally inapposite. There, we held that pris-
oners cannot use motions for “relief from a final judgment”
under Federal Rule of Civil Procedure 60(b) to circumvent
the statutory limitations on second-or-successive habeas
applications. 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 final judgment” for “any
. . . reason that justifies relief.” Fed. Rule Civ. Proc.
60(b)(6). It is a far cry from §3582(c)(1)(A), which, like
§2255, specifically 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 specific
——————
2
Preiser also reflected 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 first 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
motions. 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-
release context.

16 FERNANDEZ v. UNITED STATES
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ACKSON, J., dissenting
relief scheme and whether Congress meant for it to be can-
celled out by an implicit habeas-review bar.
Instead of acknowledging the poor fit of Preiser and Gon-
zalez, the majority doubles down, insisting that these cases
stand for “an anticircumvention principle.” Ante, at 8, n. 3.
That might well be a common thread. But the majority does
not explain why the anticircumvention principle applies to
§3582(c)(1)(A)—a statute that, unlike §1983 or Rule 60(b),
specifically authorizes the release of prisoners under given
circumstances. For the anticircumvention principle to be
apposite, one (specific) 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 specific circumstances under which the release of a
prisoner is authorized. So the circumvention concern is not
implicated 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 Fernan-
dez is essentially seeking to have his conviction vacated ra-
ther than his sentence shortened. Those are two completely

17 Cite as: 608 U. S. ____ (2026)
J
ACKSON, J., dissenting
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 define
with any precision what it means for a prisoner to “collat-
erally attac[k] the validity of his conviction.” Ante, at 1. Its
inability to do so is understandable, since delineating the
bounds of such “collateral attacks” is notoriously difficult.
Cf. W. Baude, J. Goldsmith, J. Manning, J. Pfander, & A.
Tyler, Hart and Wechsler’s The Federal Courts and the
Federal System 1687 (8th ed. 2025) (Hart & Wechsler) (dis-
cussing the difficulty 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
conviction, its lingering “concer[n]” as to his guilt was an
“extraordinary and compelling” reason for a sentence reduc-
tion. Ibid. A prisoner who proceeds through §2255,
——————
3
Seeming to acknowledge the difficulty of defining 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 re-
lease from custody.” Ante, at 16, n. 6. But context matters; before today,
this Court had not applied the Preiser line of cases to a statute that spe-
cifically authorizes release from custody. Now that the majority has ex-
tended 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)).

18 FERNANDEZ v. UNITED STATES
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ACKSON, J., dissenting
however, must show that his sentence was unlawful—spe-
cifically, that it was “imposed in violation of the Constitu-
tion or laws of the United States.” §2255(a). That is some-
thing Fernandez cannot definitively do, given this Court’s
expressed doubts about whether “a freestanding claim of
actual innocence” suffices 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” finding qualify as a collateral attack on
Fernandez’s conviction for §2255 purposes, as the majority
maintains? See ante, at 14. The District Court did not find,
for instance, that Fernandez should be released from prison
because his sentence or conviction was unconstitutional 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 difficulties arising in
other cases. Consider, for instance, a federal prisoner who
files a §2255 motion arguing that his conviction and sen-
tence are unconstitutional because a chronic mental illness
——————
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 first place and one who asserts that his pre-
sent circumstances warrant an exercise of compassion.” Ante, at 15, 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 un-
just” and citing this observation as “the basis of [its] finding that . . . Fer-
nandez ha[d] shown extraordinary and compelling circumstances for his
release”).

19 Cite as: 608 U. S. ____ (2026)
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ACKSON, J., dissenting
rendered 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
motion 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 re-
lease from prison.” Ante, at 13.
Thus, the line between a proper compassionate-release
claim and a proper habeas claim could be difficult 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 fit 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-re-
lated concerns 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 con-
sidered 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 discretion is one of degree. So, if the proffered facts
and circumstances (of whatever type) provide an “extraor-
dinary and compelling reason” to reduce the prisoner’s sen-
tence (alone or in combination), the District Court may
grant compassionate 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

20 FERNANDEZ v. UNITED STATES
J
ACKSON, J., dissenting
doubts about whether Fernandez was involved in the un-
derlying crime at all. See 2022 WL 17039059, *4.
5
Also
notable, the District Court based its §3582(c)(1)(A) ruling
on both its “disquiet” about Fernandez’s potential innocence
and the significant disparity between Fernandez’s sentence
and his codefendants’ sentences. Ibid. But due to the cat-
egorical rule the Second Circuit employed, that court did
not address whether the District Court erred in concluding
that §3582(c)(1)(A)’s “extraordinary and compelling rea-
sons” threshold was satisfied on these facts. See 104 F. 4th
420, 429–433 (2024). I would vacate the judgment below
and remand for the Second Circuit to make that assessment
in the first instance.
6
——————
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 fled to the Do-
minican Republic with his brother immediately after the shooting, while
Fernandez remained in the United States, living with his family and ac-
cruing 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
several 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.
6
Recognizing the lack of textual support for the majority’s habeas-
based rule, two Justices would affirm the Second Circuit’s ruling on a
different ground. In their view, “[a] motion for compassionate 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 cir-
cumstances that developed after sentencing.” Ante, at 1–2 (S
OTOMAYOR,
J., concurring in judgment). It is perhaps true that, in many (if not most)
cases, a compassionate-release motion rehashing old arguments and ev-
idence 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

21 Cite as: 608 U. S. ____ (2026)
J
ACKSON, J., dissenting
***
The Court’s holding in this case reflects 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
nothing about the text or history of the compassionate-re-
lease provision suggests that Congress meant for this dis-
cretionary second-look opportunity to be cabined in the way
the majority suggests. In other words, Congress gave pris-
oners an equitable “out” for the extraordinary and compel-
ling 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-
flict with §2255. The majority’s atextual and unsupported
limitation on a district court’s sentencing discretion is an
unnecessary rewriting of the statute Congress wrote and an
unwarranted revision of the compassionate-release scheme
Congress intended to establish.
——————
compassionate release, nor did the parties address it in their briefing.
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 first instance. See Cutter v. Wilkinson, 544 U. S.
709, 718, n. 7 (2005) (“[W]e are a court of review, not of first view”).