Rutherford v. United States: Oral Argument

Case Summary:Rutherford v. United States arises from Daniel Rutherford’s federal convictions for two Hobbs Act robberies and two associated firearm counts under 18 U.S.C. § 924(c), for which the district court imposed a total prison term of about 42½ years, including a “stacked” 32‑year mandatory minimum on the firearm counts (7 years for the first, 25 years for the second) plus 125 months on the robbery counts. After the First Step Act later eliminated this kind of stacking for defendants sentenced after its enactment, so that Rutherford would now face a 14‑year rather than 32‑year mandatory minimum on the same firearm conduct, he repeatedly moved in the Eastern District of Pennsylvania for compassionate release based on the large disparity between his sentence and those imposed under current law, but the district court and the Third Circuit denied relief, holding under circuit precedent that non‑retroactive changes made by the First Step Act could not constitute “extraordinary and compelling” reasons for a sentence reduction. The issue before the Supreme Court was whether, in ruling on a motion for compassionate release under 18 U.S.C. § 3582(c)(1)(A), a court may treat the large sentencing disparity created by a non‑retroactive change in federal law, specifically the First Step Act’s elimination of “stacked” § 924(c) mandatory minimums, as an “extraordinary and compelling” reason that can justify reducing a defendant’s sentence.