Fernandez v. United States · ¶26

The Second Circuit reversed, holding that “challenges to the validity of a conviction are not cognizable as `extraordinary and compelling reasons' under section 3582(c)(1)(A).” 104 F. 4th 420, 431 (2024). Congress has channeled such claims into federal postconviction proceedings under 28 U. S. C. § 2255, and by design, compassionate release and § 2255 do not overlap. “Challenging the validity of a conviction under the extraordinary-and-compelling-reasons prong of section 3582,” the court explained, “would permit a defendant to `evade the collateral review structure' of section 2255.” 104 F. 4th, at 430 (alteration omitted).

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