Carter v. United States

Questions presented

SCOTUS records, cert granted 6 Jun 2025

Congress empowered district courts to reduce sentences of federal prisoners for "extraordinary and compelling reasons." Congress did not define the terms "extraordinary and compelling" but instead expressly delegated to the United States Sentencing Commission the authority to describe what types of circumstances qualify. Exercising that authority, the Sentencing Commission adopted a provision, Section 1B1.13(b)(6), that permits district courts to consider a sentence reduction where, among other things, the defendant has served at least ten years of an unusually long sentence and a nonretroactive change in law produces a "gross disparity" between that sentence and the one likely to be imposed at the time of the motion. The Courts of Appeals are divided on the question presented here: Whether the Sentencing Commission acted within its expressly delegated authority by permitting district courts to consider, in narrowly cabined circumstances, a nonretroactive change in law in determining whether "extraordinary and compelling reasons" warrant a sentence reduction.

Opinion summary

Etalia.ai summary of the majority opinion

The case asked whether a prisoner can use Congress’s nonretroactive change to 18 U.S.C. § 924(c) as an extraordinary and compelling reason for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i). Justice Barrett wrote for the Court and held that the resulting sentencing disparity cannot qualify on its own or in combination with other factors. The Court said nonretroactive sentencing changes are ordinary, not extraordinary, and that Congress’s choice not to make the First Step Act amendment retroactive shows that the disparity is not a convincing reason to reduce an already imposed sentence. The Court also said the Sentencing Commission’s 2023 policy statement could not override the statute because policy statements must be consistent with the governing law. The judgments were affirmed.

Dissent summary

Etalia.ai summary of the dissenting opinions

Justice Sotomayor, joined by Justices Kagan and Jackson, dissented. The dissent argued that Congress gave the Sentencing Commission the primary role in defining extraordinary and compelling reasons, and that the Commission reasonably allowed courts in limited circumstances to consider sentencing disparities caused by nonretroactive changes in law. It said the Commission’s policy statement fits the statute and longstanding sentencing practice, which looks to the totality of the circumstances. The dissent disagreed with the majority’s conclusion that courts may never consider such changes when deciding compassionate release motions.