Rutherford v. United States · ¶20

They were soon forced into uncharted territory. Relevant here, courts faced a surge of motions from prisoners who invoked the Act's nonretroactive sentencing amendments as grounds for compassionate release. Most Courts of Appeals held that a nonretroactive amendment to a mandatory minimum cannot serve as an “extraordinary and compelling” reason for a reduced sentence.A minority, however, concluded that the disparity produced by such an amendment can justify a reduced sentence—at least when considered in combination with other factors.

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