Supreme Court of the United States
Fernandez v. United States
May 28, 2026225 L. Ed. 2d 26
Summary
The Court, in an opinion by Justice Barrett joined by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Kavanaugh, affirmed the Second Circuit. It held that challenges to a conviction’s validity, including claims of actual innocence, cannot constitute grounds for compassionate release under 18 U.S.C. §3582(c)(1)(A); such challenges must proceed through the federal postconviction framework. The Court left open whether freestanding actual-innocence claims are cognizable under §2255. Justice Sotomayor, joined by Justice Kagan, concurred only in the judgment, rejecting the majority’s habeas-based limitation but concluding that Fernandez could not obtain relief solely on facts already considered without postsentencing developments. Justice Jackson dissented, arguing that the statute imposes no categorical exclusion of conviction-related concerns and would have vacated and remanded for assessment of whether the circumstances justified compassionate release.
Holding
- Whether compassionate release may rest on a collateral challenge to a conviction’s validity.. A prisoner may not use §3582(c)(1)(A) to attack the validity of a conviction; the asserted invalidity is not an extraordinary and compelling reason for compassionate release.
- Whether an actual-innocence claim may support compassionate release as an exception to the collateral-review restriction.. A compassionate-release motion is not a vehicle for a freestanding actual-innocence claim. The Court did not decide whether such a claim may be brought under §2255.
Docket 24-556