Rutherford v. United States

The Court affirmed the Third Circuit, deciding that a gap between an older sentence and today’s lower sentence cannot count as an extraordinary and compelling reason to reduce a sentence when Congress made the change prospective only. The case involved the First Step Act’s changes to mandatory penalties under §924(c).

Justice Barrett wrote the 6–3 opinion, joined by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Kavanaugh; Justices Sotomayor, Kagan, and Jackson dissented.

The Court ruled 6-3. Justice Amy Coney Barrett wrote the majority opinion, joined by Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Neil Gorsuch, and Brett Kavanaugh; Justice Sonia Sotomayor dissented, joined by Justices Elena Kagan and Ketanji Brown Jackson.

Majority

Barrett

Roberts

Thomas

Alito

Gorsuch

Kavanaugh

Dissent

Sotomayor

Kagan

Jackson

“When Congress declines to make a sentencing amendment retroactive, the resulting sentencing disparity cannot serve as an “extraordinary and compelling” reason for a sentence reduction.”

Federal prisoners serving decades-long sentences under older §924(c) rules cannot seek a reduction based on that sentencing gap alone. For example, a person whose sentence would be much shorter today cannot use that difference as the reason for compassionate release (a request to reduce a prison sentence).

Lower federal courts must apply this rule when deciding compassionate-release requests based on nonretroactive sentencing changes. Prisoners affected by older §924(c) penalties cannot rely on the resulting sentencing disparity as their reason for a reduction.

The Court said a sentencing gap created by a nonretroactive law change cannot justify reducing a federal prison sentence.

Federal prisoners serving older, longer §924(c) sentences are affected. They cannot use the difference from today’s penalties as the basis for compassionate release.

Lower federal courts must follow the decision in sentence-reduction cases. They cannot treat a nonretroactive sentencing gap as an extraordinary and compelling reason.