Background
Defendants Isaac Loggins and Barton Crandall were sentenced for armed robberies involving mandatory minimum sentences under Section nine hundred twenty-four of Title eighteen of the United States Code. Congress later passed the First Step Act of two thousand eighteen, which reduced penalties for repeated violations of that statute, but the changes were not made retroactive. The defendants sought compassionate release under Section three thousand five hundred eighty-two of Title eighteen, arguing that the new policy statement regarding unusually long sentences constituted an extraordinary and compelling reason for reduction.
The court’s reasoning
The court applied the Supreme Court’s analysis in Rutherford v. United States, which concluded that nonretroactive amendments to criminal penalties are the norm and do not constitute extraordinary and compelling reasons for sentence reduction. The court held that the Sentencing Commission’s policy statement, Section one point one point one three subsection b six, exceeded its statutory authority by attempting to define reasons for release that conflict with the governing statute. The court affirmed that Congress’s decision to make the First Step Act nonretroactive must be respected, and the disparity created by such a decision is an unexceptional feature of the sentencing system.
Far from extraordinary, nonretroactive amendments to criminal penalties are the norm. Ordinarily, statutory changes to federal penalties only benefit future offenders.
Rutherford v. United States, 146 S. Ct. 1320, 1330 (2026)
What it means going forward
The ruling confirms that prisoners sentenced under prior mandatory minimums cannot obtain sentence reductions based solely on the fact that current laws would impose lower penalties, even if the Sentencing Commission has issued policy statements suggesting otherwise.