Background
Eduardo Bueno moved for compassionate release under 18 U.S.C. § 3582(c)(1)(A)(i). The U.S. District Court for the Eastern District of Virginia denied the motion on February 24, 2026.
Bueno, proceeding pro se on appeal, challenged that ruling in the Fourth Circuit. He also moved to place the appeal in abeyance.
The Court’s Holding
In an unpublished per curiam opinion, the Fourth Circuit affirmed. After reviewing the record, the panel found no abuse of discretion in the district court’s denial of compassionate release.
The court also denied Bueno’s abeyance motion as moot. It cited Fernandez v. United States for the rule that a prisoner challenging the validity of a conviction must proceed under 28 U.S.C. § 2255 rather than § 3582, and Rutherford v. United States for the holding that a sentencing disparity resulting from Congress’s nonretroactive change to § 924(c)’s mandatory penalties cannot qualify as an extraordinary and compelling reason for a sentence reduction.
Key Takeaways
- The Fourth Circuit reviewed the denial of compassionate release for abuse of discretion and found none.
- A motion under § 3582 cannot be used to collaterally attack the validity of a conviction.
- A disparity caused by a nonretroactive change to § 924(c)’s mandatory penalties cannot itself supply an extraordinary and compelling reason for relief.
Why It Matters
The decision reinforces the procedural boundary between compassionate-release motions and collateral attacks under § 2255. It also applies the Supreme Court’s 2026 guidance limiting reliance on nonretroactive § 924(c) sentencing changes as grounds for compassionate release.
Because the opinion is unpublished, it is not binding precedent in the Fourth Circuit.