Background
Federal prisoner Paul Edward Thomas appealed the Eastern District of Texas’s denial of his motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A).
Thomas argued that the district court erred by concluding that Fifth Circuit precedent prevented U.S.S.G. § 1B1.13(b)(6) from authorizing relief. That policy statement addressed certain unusually long sentences in light of changes in law. After appellate briefing concluded, however, the Supreme Court decided Rutherford v. United States.
The Court’s Holding
The Fifth Circuit held that Rutherford foreclosed Thomas’s arguments. Rutherford determined that the First Step Act’s nonretroactive amendment to 18 U.S.C. § 924(c), whether considered alone or with other factors, cannot constitute an extraordinary and compelling reason for compassionate release under § 3582(c)(1)(A).
Rutherford also held § 1B1.13(b)(6) invalid to the extent it provided otherwise. The government therefore moved for summary affirmance, Thomas agreed that summary affirmance was appropriate, and the Fifth Circuit granted the motion and affirmed the district court’s order.
Key Takeaways
- A nonretroactive change to § 924(c) cannot support compassionate release, either by itself or in combination with other circumstances.
- U.S.S.G. § 1B1.13(b)(6) is invalid to the extent it treats that change in law as an extraordinary and compelling reason for relief.
- Because Rutherford directly foreclosed Thomas’s appellate arguments, the Fifth Circuit resolved the appeal through summary affirmance.
Why It Matters
The decision applies Rutherford in the Fifth Circuit and confirms that prisoners cannot use compassionate-release motions to obtain the benefit of the First Step Act’s nonretroactive § 924(c) amendment. It also limits reliance on § 1B1.13(b)(6) when the policy statement conflicts with Rutherford.