Drawing on a centuries-long tradition of granting wide discretion to judges when imposing sentences, the Sentencing Reform Act of 1984 allows federal judges to reduce a previously imposed sentence when they conclude that there are “extraordinary and compelling reasons” to do so. Petitioners in these cases moved for reductions in their sentences under the Sentencing Reform Act because of significant difference between the sentences they are serving and the sentences that they would have received if they were sentenced for those same offenses today.

The petitioners are serving federal sentences under § 924(c), which criminalizes the use of a firearm in furtherance of drug trafficking or a crime of violence. When they were initially sentenced under § 924(c), the law required judges to impose a 25-year minimum sentence for each § 924(c) violation after the first, even if the defendant was convicted for both violations at the same time. Because this interpretation led to sentences that many judges felt were unjust, Congress enacted the First Step Act to clarify that judges are not required to impose these sorts of stacked sentences when sentencing first-time offenders. If the petitioners had been sentenced after the First Step Act’s enactment, their sentences would have been significantly shorter.

According to the court below, the sentencing judges in the petitioners’ cases could not consider the decades-long disparity between the petitioners’ sentences and those of individuals who commit similar crimes today when assessing whether “extraordinary and compelling reasons” exist for a sentence reduction. In August 2025, CAC filed an amicus brief explaining that this position is at odds with both the text and history of the compassionate release statute.

The text of § 3582(c)(1)(A) of the Sentencing Reform Act gives judges broad discretion to determine the existence of “extraordinary and compelling reasons” for a sentence reduction. The statute contains only one instruction about the scope of judges’ authority to assess the “extraordinary and compelling reasons” for compassionate release: courts must abide by the Sentencing Commission’s policy statements. And in tasking the Sentencing Commission with providing guidance on what should be considered “extraordinary and compelling reasons,” it provides only one stipulation: “[r]ehabilitation of the defendant alone shall not be considered an extraordinary and compelling reason.” The clear inference is that other reasons are permissible within a judge’s discretion.

Congress’s use of the phrase “extraordinary and compelling” bears this out. In 1984, the phrase “extraordinary and compelling reasons” connoted determinations that were broad, individualized, and fact-dependent. The plain language of the statute indicates that the sentencing judge should make an individualized assessment of the case, considering all relevant factors, to decide whether there were “extraordinary and compelling reasons” to reduce the individual’s sentence, and no factors other than rehabilitation alone should be categorically excluded. Legal dictionaries and case law at the time reinforce this definition.

Section 3582(c)(1)(A)’s history confirms the broad discretion it grants to sentencing judges. Before the Sentencing Reform Act of 1984, courts imposed the sentence, but parole officers exercised absolute discretion over the actual duration of imprisonment. Congress felt that the system of indeterminate sentencing had unjustified consequences, like creating uncertainty as to the time an offender would actually spend in prison, producing serious disparities between sentences imposed for similar offenses, and letting parole boards usurp the function of the judiciary. In response to these concerns, the Sentencing Reform Act of 1984 revolutionized the federal sentencing scheme, creating a more structured system with a compassionate release provision acting as a “safety valve” in unusual cases. Lawmakers described this safety valve authority as a response to judges’ requests for the power to deal with what one congressman described as “the very exceptional situation where someone obviously slips through the cracks and gets a much longer sentence.” In granting judges this “safety valve” authority, Congress ensured that they would have the same broad discretion to consider a wide variety of different factors that parole officials had enjoyed under the previous regime.

The First Step Act does not provide grounds for courts to write a prohibition on considering disparities in § 924(c) sentences into § 3582(c)(1)(a). In 2018, Congress enacted the First Step Act, which “clarif[ied]” that district court judges are not required to impose stacked 25-year sentences when sentencing first-time offenders under § 924(c) and provided that these amendments “shall apply to any offense that was committed before” the First Step Act’s enactment. According to the court below, courts cannot consider the fact of the First Step Act’s change to § 924(c) in the compassionate release eligibility context because doing so would “sow conflict within the statute.” This is wrong. Though the First Step Act provided that “the changes to the § 924(c) mandatory minimums would not apply to people who had already been sentenced,” considering the fact of an amended penalty when assessing whether “extraordinary and compelling reasons” exist for a sentence reduction is not the same as applying the amended penalty. A sentence reduction is not an application of the First Step Act at all—if that were the case, the court would not need to find “extraordinary and compelling reasons” for the reduction. The history of parole and other “safety valve” mechanisms also makes clear that disparities between the penalty a defendant received and those applied to people who committed similar offenses can be considered under § 3582(C)(1)(A). Indeed, this history illustrates that parole decisionmakers were responsive to changes in how society perceived an offense over time, meaning that disparities produced by Congress’s decision to reduce a penalty would be especially relevant to their decisions.

The court below was wrong to prohibit the sentencing judges from considering major changes in the law that result in sentencing disparities solely based on when a person was sentenced, and the Supreme Court should reverse.