Second Circuit reverses Fernandez compassionate release grant, ruling § 3582 cannot substitute for habeas corpus

A Second Circuit panel reversed Judge Rakoff's compassionate release grant for Jose Fernandez, holding that doubts about conviction validity do not constitute an "extraordinary and compelling reason" under 18 U.S.C. § 3582(c)(1)(A). The panel ruled that § 3582 is a sentence-modification statute, not a mechanism for collaterally attacking the underlying conviction, and that allowing such attacks through compassionate release would circumvent Congress's strict rules for successive habeas petitions under 28 U.S.C. § 2255. Fernandez petitioned the Supreme Court for certiorari.