Rutherford v. United States

Questions presented

SCOTUS records, cert granted 6 Jun 2025

The compassionate-release statute permits courts to reduce a prisoner's sentence if the court finds that "extraordinary and compelling reasons" warrant relief. 18 U.S.C. § 3582(c)(1)(A). Congress placed only two limits on what can count as an "extraordinary and compelling reason": (1) it must be "consistent with" "applicable policy statements" from the U.S. Sentencing Commission, id.; and (2) "[r]ehabilitation of the defendant alone shall not be considered an extra- ordinary and compelling reason," 28 U.S.C. § 994(t). Sections 401 and 403 of the First Step Act of 2018 reduced penalties for certain drug and firearm offenses going forward. Because of these changes, individuals sentenced today for these offenses often face mandatory minimum terms of imprisonment decades shorter than they would have received before the First Step Act. The question presented is: Whether, as four circuits permit but six others prohibit, a district court may consider disparities created by the First Step Act's prospective changes in sentencing law when deciding if "extraordinary and compelling reasons" warrant a sentence reduction under 18 U.S.C. § 3582(c)(1)(A)(i).

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.