Fernandez v. United States

Majority — Barrett

Joined by: Roberts, Thomas, Alito, Gorsuch, Kavanaugh

The majority held that Congress specifically designed 28 U.S.C. §2255 — with its one-year deadline, strict limits on repeat filings, and other procedural hurdles — as the exclusive path for prisoners to challenge the validity of their federal convictions, and that allowing prisoners to use the compassionate release statute instead would let them bypass all of those requirements. The Court reasoned that its prior decisions in Preiser v. Rodriguez and Gonzalez v. Crosby established a principle that challenges "close to the core of habeas corpus" must go through the habeas process, even if another statute's broad language might technically allow them. The majority also pointed to the text and structure of the compassionate release statute itself: its name, its focus on personal circumstances like terminal illness and old age, and the central role of the Bureau of Prisons — whose expertise is in prisoners' daily lives, not legal arguments — all indicate that Congress designed it to grant mercy, not to correct legal errors. The Court further noted that the Sentencing Commission, which has issued policy guidance on compassionate release for decades, has never identified a flawed conviction as a qualifying reason for early release. Finally, the majority observed that when a conviction is truly invalid, the proper remedy is to vacate it entirely under §2255 — not to simply shorten the sentence, which does not fully address the wrong.

Dissent reasoning

In dissent, Justice Jackson argued that the majority's rule has no basis in the text of the compassionate release statute, which says nothing about habeas corpus or §2255 and simply authorizes sentence reductions for "extraordinary and compelling reasons." The dissent contended that those words speak to the degree of a circumstance — how unusual and forceful it is — not to the type of circumstance, meaning no category of reason is categorically off the table. Justice Jackson argued that the prior cases the majority relied on (Preiser and Gonzalez) involved general civil statutes being used to sidestep specific habeas rules, whereas §3582 is itself a specific criminal-sentencing statute — making the analogy a poor fit. The dissent also raised the example of a prisoner who is factually innocent but has no available constitutional claim that would qualify for habeas relief, arguing that the compassionate release statute would be the only available safety valve for such a person, and that the majority's rule forecloses even that. Justice Jackson further warned that the majority's new line — between a "collateral attack on a conviction" and a "compelling bid for compassion" — is fuzzy and will be difficult for lower courts to apply consistently, potentially blocking legitimate claims simply because they resemble habeas arguments.