United States v. Austin, 125 F.4th 688

Stokley Austin pleaded guilty to conspiracy to distribute cocaine and received a 20-year mandatory minimum sentence under 21 U.S.C. § 841(b)(1)(A) (2010).
Congress later reduced the mandatory minimum for this offense to 15 years via the First Step Act of 2018, explicitly making this reduction non-retroactive.
Austin, whose sentence was already imposed, filed for compassionate release under 18 U.S.C. § 3582(c)(1), arguing the non-retroactive change should count as an extraordinary and compelling reason for release.
The district court denied Austin's motions, ruling he failed to present an extraordinary and compelling reason for sentence reduction.
Austin appealed, and the appellate court reviewed legal questions de novo and the compassionate release denial for abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can a non-retroactive change in law be an	Austin: Yes; a non-retroactive legal	USA: No; such changes affect all	No; non-retroactive changes are not extraordinary or compelling
extraordinary and compelling reason for	change is an extraordinary and	similarly situated prisoners and are	reasons to reduce sentence under § 3582(c)(1) according to binding
compassionate release under § 3582(c)(1)?	compelling reason, since Austin would	neither unique nor unforeseeable.	precedent.
	benefit if sentenced today.

United States v. Escajeda, 58 F.4th 184 (5th Cir. 2023) (establishes that non-retroactive changes in law do not constitute extraordinary or compelling reasons for compassionate release)
United States v. LaBonte, 520 U.S. 751 (1997) (guidelines must follow specific congressional directives)
Stinson v. United States, 508 U.S. 36 (1993) (Sentencing Commission cannot interpret guidelines inconsistently with statutes)
Neal v. United States, 516 U.S. 284 (1996) (agencies cannot amend judicial construction of statutes)
United States v. Koons, 850 F.3d 973 (8th Cir. 2017) (Sentencing Commission cannot override non-retroactivity of statutes)