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COMPASSIONATE RELEASE

Rutherford v. United States

Issues

Can a district court consider sentencing disparities created by the First Step Act when deciding whether compassionate release is warranted by “extraordinary and compelling reasons?”

 

This case asks the Supreme Court to determine whether the compassionate release provision of the Sentencing Reform Act allows courts to consider disparities created by the First Step Act’s prospective reduction in mandatory minimum sentences. Petitioner Daniel Rutherford argues that the phrase “extraordinary and compelling” invites a totality of the circumstances analysis utilizing any relevant facts, including sentencing length and changes in law. Respondent United States counters that change in law disparities are not “extraordinary and compelling reasons” under the plain meaning of the statute. The outcome of this case will impact the separation of powers between branches of government as well as the mechanisms for remedying sentence disparities.

Questions as Framed for the Court by the Parties

Whether a district court may consider disparities created by the First Step Act’s prospective changes in sentencing law when deciding if “extraordinary and compelling reasons” warrant a sentence reduction under 18 U.S.C. § 3582(c)(1)(A)(i).

As part of the Sentencing Reform Act of 1984 (“SRA”), Congress enacted a “compassionate release” provision that allows district courts to reduce prison sentences. 

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