We will hear argument first this morning in case 24556, Fernandez v. United States.

Mr. Groenstein.

Mr. Chief Justice, and may it please the Court, when Congress established the extraordinary and compelling reason standard

for sentence reductions under Section 3582, it shows words that set a high bar for when courts may grant such motions.

It also chose words that do not prescribe what types of reasons will qualify. Instead, it delegated that

task to the Sentencing Commission and required that district courts comply with the Commission's

guidance when exercising their discretion under the statute.

This case presents the question whether Congress has implicitly prohibited district courts and the Sentencing Commission

from considering any reasons that may also be alleged as grounds for habeas relief. It has not. Under the plain

meaning of the statute, if a court finds an error that significantly increase the length of the

defendant's sentence, that fact can contribute to a finding of extraordinary and compelling

reasons to reduce the sentence. And even when a court finds no error, it may nonetheless decide that the circumstances

surrounding the defendant's sentence were so unusual and unfair as to be extraordinary

and compelling. That's what happened here.

The government's position is extreme.

It contends that no argument related to a defendant's judgment may even be considered in the extraordinary and compelling calculus.

It posits that only personal circumstances like age and illness are relevant.

Our position is modest.

We recognize that personal circumstances are common reasons that courts find to be extraordinary and compelling. But we reject the

government's view that courts can never consider an error or unfairness in a defendant's

sentence in that analysis. Allowing courts to grant a sentence reduction in rare cases based in part on circumstances

that could have been addressed on habeas will not frustrate the habeas statute's procedural

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