Fernandez v. United States
608 U. S. 411 (2026) · 5/28/26
A prisoner who collaterally attacks the validity of his conviction must proceed through 28 U. S. C. §2255, not 18 U. S. C. §3582; the supposed invalidity of a conviction is not among the “extraordinary and compelling reasons” that justify compassionate release.
Edition: preliminary print (page proof)
Voices: Syllabus — prepared by the Reporter of Decisions · Justice Barrett delivered the opinion of the Court. · Justice Sotomayor, with whom Justice Kagan joins, concurring in the judgment. · Justice Jackson, dissenting.
Joe Fernandez was indicted in 2013 for his role in the assassination of two gang members. The prosecution's theory was that members of a drug ring had paid Fernandez to act as the backup shooter, and when the primary shooter's gun jammed, Fernandez fred 14 rounds and killed both victims. Fernandez's alleged co-conspirator, Patrick Darge, testified against Fernandez at trial. The jury convicted Fernandez of murder for hire and a frearms offense, and the District Court imposed two consecutive life sentences. Fernandez pursued multiple avenues of relief. He first asked the District Court to…
Held: A prisoner who collaterally attacks the validity of his conviction must proceed through 28 U. S. C. § 2255, not 18 U. S. C. § 3582; the supposed invalidity of a conviction is not among the “extraordinary and compelling reasons” that justify compassionate release. Pp. 419–430. (a) Section 2255 governs collateral attacks on federal convictions and imposes tight procedural constraints, including: a 1-year statute of limitations, §2255(f); a general rule that prisoners get only one shot at collateral relief with narrow exceptions, §§ 2255(h)(1)–(2); a bar on relitigating claims already…Read it in the reading room ›