The question
Whether a federal prisoner may attack the validity of his conviction through a motion for compassionate release under 18 U.S.C. §3582 rather than through the collateral-review procedure of 28 U.S.C. §2255.
Fernandez v. United States
What the Court decided
The Court held that a federal prisoner who collaterally attacks the validity of his conviction must proceed under 28 U.S.C. §2255, not through a compassionate-release motion under 18 U.S.C. §3582. The alleged invalidity of a conviction is not among the "extraordinary and compelling reasons" that justify compassionate release. Section 2255 imposes tight procedural constraints, including a one-year limitations period and limits on successive motions, that §3582 cannot be used to bypass.
How the justices split
8-1The Court's opinion
Barrett, joined by Roberts, Thomas, Alito, Gorsuch, Kavanaugh
Section 2255 governs collateral attacks on federal convictions and imposes tight procedural constraints, including a one-year statute of limitations, a general rule limiting prisoners to a single collateral motion with narrow exceptions, a bar on relitigating claims already raised and rejected, and procedural-default rules. Compassionate release under §3582 requires only that the prisoner first present his request to the Bureau of Prisons, and its extraordinary-and-compelling-reasons standard does not encompass the claimed invalidity of a conviction. A prisoner may not use §3582 to bypass the constraints Congress placed on §2255.
Concurring in the judgment
Sotomayor, joined by Kagan
Sotomayor agreed with the judgment that Fernandez could not obtain relief but wrote separately to state her own reasoning for that outcome.
Dissenting
Jackson, writing alone
Jackson disagreed with the Court's conclusion that a prisoner may not raise the invalidity of a conviction through a compassionate-release motion under §3582.
How we know · 5 sourced claims
The Court held that a prisoner collaterally attacking the validity of his conviction must proceed through 28 U.S.C. §2255, not 18 U.S.C. §3582.
Source: syllabus, Held
The supposed invalidity of a conviction is not among the extraordinary and compelling reasons that justify compassionate release.
Source: syllabus, Held
Section 2255 imposes procedural constraints including a one-year statute of limitations and a general rule limiting prisoners to a single collateral motion.
Source: syllabus, Held
The sole procedural requirement imposed by §3582 is that the prisoner first present his request to the Bureau of Prisons.
Source: syllabus, Held
Barrett delivered the opinion of the Court, joined by Roberts, Thomas, Alito, Gorsuch, and Kavanaugh; Sotomayor concurred in the judgment joined by Kagan; Jackson dissented.
Source: syllabus, lineup