Summary
The Supreme Court held that a federal prisoner challenging the validity of a conviction must proceed under 28 U.S.C. § 2255 rather than seek compassionate release under 18 U.S.C. § 3582(c)(1)(A). The Court concluded that the alleged invalidity of a conviction is not an extraordinary and compelling reason warranting compassionate release because allowing such claims would circumvent the procedural requirements governing collateral attacks. The Court affirmed the judgment of the United States Court of Appeals for the Second Circuit.
Topics
Practice areas
Questions Presented
- Whether a federal prisoner may use a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i) to collaterally attack the validity of his conviction.
- Whether alleged actual innocence may constitute an extraordinary and compelling reason for compassionate release under § 3582(c)(1)(A)(i).
Holdings
- A prisoner who collaterally attacks the validity of a federal conviction must proceed through 28 U.S.C. § 2255, not 18 U.S.C. § 3582(c)(1)(A). The supposed invalidity of a conviction is not an extraordinary and compelling reason warranting compassionate release.
- A compassionate-release motion is not a vehicle for raising an actual-innocence claim because an assertion of actual innocence challenges the validity of the conviction and therefore lies close to the core of habeas corpus.
Key quotations
“A prisoner who collaterally attacks the validity of his conviction must proceed through 28 U. S. C. §2255, not 18 U. S. C. §3582.” (at 1)
“The compassionate release provision is not a vehicle for attacking the validity of a conviction.” (at 17)
Factual background
Fernandez was convicted of murder for hire and a firearms offense after evidence that he acted as a backup shooter in the assassination of two gang members. His alleged co-conspirator, Patrick Darge, testified against him, while Fernandez challenged Darge's credibility and the Government's treatment of another alleged co-conspirator, Luis Rivera. After one firearms conviction was vacated under United States v. Davis, the district court granted compassionate release based on renewed doubts about Darge's testimony, the prosecution's charging decisions, and the correctness of the murder-for-hire verdict.
Procedural history
Fernandez was convicted in the Southern District of New York of murder for hire and a firearms offense and received two consecutive life sentences. The Second Circuit affirmed his conviction and sentence, and Fernandez later pursued two motions under 28 U.S.C. § 2255; the second resulted in vacatur of the firearms conviction under United States v. Davis, but his murder-for-hire conviction remained. The district court granted compassionate release under § 3582(c)(1)(A)(i) based primarily on doubts about the conviction, but the Second Circuit reversed. The Supreme Court affirmed.