Supreme Court Rules Compassion Release Can’t Substitute for Post-conviction Relief

In Fernandez v. United States, 608 U.S. ____ (2026), the U.S. Supreme Court held that federal prisoners cannot use the compassionate release statute—18 U.S.C. § 3582(c)(1)(A)—to challenge the validity of their conviction or sentence. Instead, prisoners seeking to challenge the legality or validity of their conviction must proceed through 28 U.S.C. § 2255.

Facts of the Case

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 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 Court of Appeals affirmed the conviction and sentence, rejecting both the Brady claim and Fernandez’s insufficiency-of evidence 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 (2019), thus leaving in place Fernandez’s murder-for-hire conviction. In the order vacating the firearms 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.”

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 reduction. The District Court granted the motion, citing unease about 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.

Supreme Court’s Decision

The Supreme Court affirmed by a vote of 8-1. “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,” Amy Coney Barrett wrote on behalf of the Court. “A prisoner who collaterally attacks the validity of his conviction must proceed through 28 U. S. C. §2255, not 18 U.S.C. §3582.”

In reaching its decision, the Court emphasized that the Court’s precedents establish that claims “close to the core of habeas corpus” must be brought under “the specific federal habeas corpus statute” prescribed for relief and other statutes “must be read in harmony” with the habeas framework. As Justice Barrett wrote, “A contrary result would allow prisoners to evade §2254’s requirements.”

The Court went on to find that a compassionate release motion can’t be used to avoid §2255’s procedural and substantive requirements. “Fernandez has pursued a collateral attack outside the rigorous habeas framework,” Justice Barrett wrote. “And as in those cases, the workaround is impermissible. Challenging the validity of a conviction through a compassionate release motion circumvents the exacting requirements of §2255.”

In further support of its holding, the Court cited the text and structure of §3582, noting that “extraordinary” 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 forcefulness of evidence.” Moreover, the name for §3582(c)(1)(A)—“Compassionate Release”—highlights its focus on granting mercy rather than righting legal wrongs. Justice Barrett wrote:

Congress made compassionate release available only when “extraordinary and compelling reasons” justify it. 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.” Seen in that light, the supposed invalidity of a conviction is not among the “extraordinary and compelling reasons” that justify compassionate release.

Finally, the Court found that Fernandez’s argument that §2255 and §3582 offer different forms of relief does not help him. As Justice Barrett noted, the difference in relief highlights the “mismatch” between the error he alleges and the remedy he seeks.