Fernandez v. United States (24-556)
- Term
- OT 2025
- Argued
- 2025-11-12
- Decided
- 2026-05-28
- Vote
- 8-1 for United States
- Opinion
- Justice Barrett
- Majority
- Roberts, Thomas, Alito, Gorsuch, Kavanaugh, Barrett
- Dissent
- Jackson
The case in brief
Facts
Joe Fernandez was charged in 2013 for his role in the killing of two gang members, and a jury convicted him of murder for hire and a firearms offense. The trial judge gave him two life sentences, to be served one after the other. Fernandez challenged his conviction on appeal and then twice under 28 U.S.C. §2255, the main federal law for attacking a conviction after an appeal; only his firearms conviction was thrown out, and his murder-for-hire conviction stayed in place. He then asked for "compassionate release" (an early release from prison), arguing mainly that he was innocent, and the trial judge granted it, citing doubts about a key witness and about the jury's verdict. The Second Circuit appeals court reversed, ruling that challenges to a conviction's validity cannot count as reasons for compassionate release, and the Supreme Court took the case to settle a split among the appeals courts.
Question
Can a federal prisoner argue that his conviction was invalid as an "extraordinary and compelling reason" to get his sentence reduced under the federal compassionate-release law?
Conclusion
The United States won by an 8-1 vote, in an opinion by Justice Barrett. The Court held that a prisoner who wants to challenge whether his conviction was valid must use §2255, not the compassionate-release law, because otherwise prisoners could sidestep §2255's strict limits, such as deadlines and limits on repeat filings. Justice Sotomayor, joined by Justice Kagan, agreed only with the result, on a narrower ground: compassionate release cannot rest only on facts the court already considered at sentencing. Justice Jackson dissented, arguing that the Court added a limit that the law's text does not contain.
Opinion of the Court
Authored by Justice Barrett (14,494 words total).
Volume 608 U. S. Part 2 Pages 411–453
THE SUPREME COURT May 28, 2026
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certiorari to the united states court of appeals for the second circuit No. 24–556. Argued November 12, 2025—Decided May 28, 2026 Joe Fernandez was indicted in 2013 for his role in the assassination of two gang members. The prosecution's theory was that members of a drug ring had paid Fernandez to act as the backup shooter, and when the primary shooter's gun jammed, Fernandez fred 14 rounds and killed both victims. Fernandez's alleged co-conspirator, Patrick Darge, testifed against Fernandez at trial. The jury convicted Fernandez of murder for hire and a frearms offense, and the District Court imposed two consecutive life sentences. Fernandez pursued multiple avenues of relief. He frst asked the 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 concluded that they did not contain relevant information, though the judge noted he was “troubled” by the Government's lenient treatment of Rivera. The Second Circuit affrmed the conviction and sentence, rejecting both the Brady claim and Fernandez's insuffciency-of-evidence argument. It held that a reasonable jury could credit Darge's testimony and that the evidence was suffcient to support conviction. Fernandez then twice moved for postconviction relief under 28 U. S. C. § 2255. The frst motion, arguing actual innocence based on witness credibility, was described by the Second Circuit as “plainly meritless.” The second succeeded only in vacating his frearms conviction based on United States v. Davis, 588 U. S. 445, thus leaving in place Fernandez's murder-forhire conviction. In the order vacating the frearms conviction, the District Judge speculated that the Government had offered Rivera a lenient plea deal because it “kn[ew] something” inconsistent with Darge's testimony, and pointedly noted that if Fernandez's life sentence on the murder-for-hire charge “were to be commuted, or held unlawful, [Fernandez] would be released immediately.” 569 F. Supp. 3d 169, 174, n. 4, 179. Fernandez fnally fled a motion for compassionate release under 18 U. S. C. § 3582(c)(1)(A)(i), arguing that extraordinary and compelling reasons—above all, that he was innocent—warranted a sentencing reduction. The District Court granted the motion, citing unease about
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whether Darge's testimony had been truthful, concerns about the Government'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 supposed invalidity of a conviction is not among the “extraordinary and compelling reasons” that justify compassionate release. Pp. 419–430. (a) Section 2255 governs collateral attacks on federal convictions and imposes tight procedural constraints, including: a 1-year statute of 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 default rules requiring demonstration of “ `cause' ” and “ `prejudice' ” or actual 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 fled a motion presenting similar arguments under 18 U. S. C. § 3582, which permits prisoners to seek compassionate release from prison by showing “extraordinary and compelling reasons” warrant early release. Unlike the procedural constraints on § 2255 claims, the sole procedural requirement imposed by § 3582 is that the prisoner must frst present his request to the Bureau of Prisons. The Court's precedents establish that claims “close to the core of habeas corpus” must be brought under “the specifc federal habeas corpus statute” prescribed for relief, Preiser v. Rodriguez, 411 U. S. 475, 489, and other statutes “must be read in harmony” with the habeas framework, District Attorney's Offce for Third Judicial Dist. v. Osborne, 557 U. S. 52, 66. In Preiser, the Court held that even though prisoners' claims “came within the literal terms” of 42 U. S. C. § 1983, Congress's determination “that habeas corpus is the appropriate remedy for state prisoners attacking the validity of the fact or length of their confnement” “must override the general terms of § 1983.” 411 U. S., at 490. A contrary result would allow prisoners to evade the rigorous requirements of postconviction relief and “wholly frustrate explicit congressional intent.” Id., at 489. In Gonzalez v. Crosby, 545 U. S. 524, the Court held that prisoners may not use Federal Rule of Civil Procedure 60(b) to argue that a denial of habeas relief was wrong on the merits,
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