Fernandez v. United States, 608/2

Fernandez was convicted of murder for hire and a firearms offense for acting as a backup shooter in a gang assassination, and he received two consecutive life sentences. 1
His direct appeal and initial postconviction challenges, including Brady and sufficiency arguments and a §2255 actual-innocence claim, were rejected. 2
A later §2255 motion succeeded only in vacating the firearms conviction under United States v. Davis, leaving the murder-for-hire conviction intact. 3
Fernandez then sought compassionate release under §3582(c)(1)(A), arguing that doubts about his innocence and the verdict were extraordinary and compelling reasons for reduction. 4
The district court granted relief based on doubts about Darge's testimony and the verdict, but the Second Circuit reversed, holding conviction-validity challenges are not cognizable under §3582. 5
The Supreme Court affirmed, holding that collateral attacks on a conviction must proceed under §2255, not compassionate release. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can compassionate release challenge conviction validity? 7	Fernandez said innocence and verdict doubts were extraordinary and compelling.	The Government said conviction attacks belong only under §2255.	No; §3582 cannot be used to attack conviction validity. 8
Does §3582 let prisoners bypass §2255 limits? 9	Fernandez said §3582 provides different relief and avoids §2255 hurdles.	The Government said that would circumvent habeas restrictions.	No; such use would evade §2255's strict scheme. 10
Do actual-innocence claims qualify as compassionate-release reasons? 11	Fernandez argued actual innocence must be cognizable under §3582.	The Government said innocence still attacks conviction validity.	No; actual innocence is not a compassionate-release shortcut. 12

Preiser v. Rodriguez, 411 U.S. 475 (U.S. 1973) (habeas is the specific remedy for prisoners attacking confinement validity 13)
District Attorney's Office for Third Judicial Dist. v. Osborne, 557 U.S. 52 (U.S. 2009) (statutes affecting confinement must be read in harmony with habeas 14)
Gonzalez v. Crosby, 545 U.S. 524 (U.S. 2005) (Rule 60(b) cannot be used to circumvent habeas limits 15)
Kaufman v. United States, 394 U.S. 217 (U.S. 1969) (claims rejected on direct review generally cannot be relitigated in §2255 16)
Bousley v. United States, 523 U.S. 614 (U.S. 1998) (procedural default requires cause and prejudice or actual innocence 17)
Herrera v. Collins, 506 U.S. 390 (U.S. 1993) (actual innocence challenges conviction validity 18)
United States v. Davis, 588 U.S. 445 (U.S. 2019) (vague residual clause required vacatur of a firearms conviction 19)