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The Tenth Seat
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DecidedOpinion v1.0

Fernandez v. United States

No. 24-556 · OT 2025

Question presented

Whether a combination of 'extraordinary and compelling reasons' that may warrant a discretionary sentence reduction under 18 U.S.C. § 3582(c)(1)(A) can include reasons that may also be alleged as grounds for vacatur of a sentence under 28 U.S.C. § 2255.

Background

After Fernandez's mandatory life sentence on a 2013 cartel-murder conviction was reduced to time served under § 3582(c)(1)(A)(i) — based on the same district judge's accumulated 'disquiet' about the verdict and a co-defendant sentencing disparity — the Second Circuit reversed. It held that any reason 'in substance' challenging the validity of a conviction or sentence is reserved exclusively to § 2255 with its AEDPA-calibrated procedural limits, and that § 2255 is the 'more specific' statute. Fernandez argues that 'extraordinary and compelling reasons' are terms of degree, not kind; that § 994(t)'s express rehabilitation-alone bar is the only categorical limit Congress enacted; and that § 3582(b)'s preservation of the conviction's finality places § 3582 motions outside Heck's 'necessarily imply invalidity' channeling rule. The Government's brief framed the exclusion as reaching claims 'cognizable under § 2255'; at oral argument it reformulated the rule to reach any 'asserted reason that attacks the validity of the conviction or sentence,' a switch Justices Kagan and Barrett pressed it on directly.

Procedural posture

Argued
November 12, 2025
Decided
May 28, 2026
Tenth Seat opinion published
May 14, 2026
Term
OT 2025

The Tenth Seat