The legal question is whether Patrick Dewayne Smith’s 2024 compassionate-release order can stand after a Supreme Court ruling issued in May. Smith had served 13 years of a life sentence when a federal judge released him. In September, prosecutors challenged the order, arguing that the ruling undermined its legal basis. The case’s outcome could determine whether Smith remains free.
The ruling and Smith’s release
In Rutherford v. United States, the Supreme Court ruled 6-3 that a sentencing disparity created by later, nonretroactive changes in law cannot, on its own, qualify as an “extraordinary and compelling” reason for compassionate release. Justice Amy Coney Barrett wrote that Congress’s choice not to apply reduced penalties to people already sentenced is not, by itself, a sufficient basis for a reduction. The Court considered whether judges could weigh First Step Act sentencing changes in compassionate-release decisions, as summarized in the Cornell Law School Legal Information Institute’s case materials.
Smith’s request relied on Sentencing Commission rules adopted in 2023, which allowed judges in some circumstances to consider changes in law for people who had served at least 10 years. After nearly a year, a judge granted his request and released him in 2024. Prosecutors argue that under current law Smith would face a 25-year mandatory minimum and that the release decision is difficult to justify, according to the Associated Press report.
How Smith received a life sentence
The AP reported that Smith’s federal drug conviction, together with his earlier record, led to a life sentence. He had previously served about three years in prison for marijuana convictions. In the later case, he was convicted of conspiring to distribute drugs and money laundering after withdrawing from a plea agreement that would have called for 12 to 14 years in prison in exchange for cooperation. His sentence was the longest among 20 defendants in the case.
The First Step Act reduced some mandatory minimum sentences but did not make those reductions retroactive. The Sentencing Commission’s policy change followed that law. In Rutherford, Daniel Rutherford received a sentence of about 42 and a half years; had the later law applied when he was sentenced, the mandatory minimum for his two firearms convictions would have been 14 years rather than 32, according to the Cornell case summary.
How often do judges grant compassionate release?
A U.S. Sentencing Commission analysis found that in fiscal 2020, courts granted sentence reductions to 1,805 of the 7,014 offenders whose compassionate-release motions they decided (25.7%). That snapshot largely reflects the early COVID-19 pandemic period. The Commission reported that courts cited COVID-19 health risks as at least one reason for granting relief in 71.5% of those cases, so the figure describes pandemic-era grants rather than the reasons for current cases. Both findings are from the U.S. Sentencing Commission.
The AP reported that the Department of Justice had argued against the Sentencing Commission’s approach and that judges nevertheless granted release to dozens of people after considering legal changes alongside other factors. FAMM, a sentencing reform group, estimates that about a dozen people could be affected by the Supreme Court decision. The AP report was written by Lindsay Whitehurst, with video journalism by Kristin M. Hall in Nashville; the Smith-specific case details in this article rely on that reporting.
