Fernandez v. United States

The Supreme Court ruled that federal prisoners cannot use compassionate release to challenge whether their convictions are legally valid. Those challenges must go through Section 2255, a federal procedure for prisoners challenging convictions or sentences after trial.

Justice Barrett wrote the 8–1 opinion, joined by Chief Justice Roberts and Justices Thomas, Alito, Kagan, Gorsuch, and Kavanaugh; Justice Sotomayor concurred; Justice Jackson dissented.

Justice Amy Coney Barrett wrote the Court's 8-1 opinion affirming the Second Circuit. Justice Sonia Sotomayor concurred, and Justice Ketanji Brown Jackson dissented.

Majority

Barrett

Roberts

Thomas

Alito

Sotomayor

Kagan

Gorsuch

Kavanaugh

Dissent

Jackson

““The supposed invalidity of a conviction is not among the ‘extraordinary and compelling reasons’ that justify compassionate release.””

Federal prisoners seeking a shorter sentence cannot use compassionate release as a substitute for a Section 2255 challenge. For example, a prisoner claiming a conviction was invalid must use the Section 2255 process instead.

Lower federal courts will apply this rule when prisoners seek compassionate release based on attacks on their convictions. Prisoners pursuing those claims must instead use the Section 2255 process.

The Court said compassionate release cannot be used to challenge a conviction's validity. Such claims must proceed under Section 2255.

Federal prisoners seeking sentence reductions based on claims their convictions are invalid are affected. They must use Section 2255 rather than compassionate release.

Lower courts must follow the decision in compassionate-release cases. Prisoners challenging convictions must pursue the separate Section 2255 process.