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# Supreme Court Ruling Puts Freed Tennessee Man at Risk of Return
- URL: https://www.theamericanquorum.com/supreme-court-ruling-puts-freed-tennessee-man-at-risk-of-return/
- Published: 2026-10-12T04:09:44.000Z
- Updated: 2026-10-12T04:09:44.000Z
- Description: A May Supreme Court ruling has put Patrick Dewayne Smith’s 2024 release in jeopardy, testing whether roughly a dozen people freed under First Step Act sentencing rules can be returned to federal prison.
- Author: News Desk
- Tags: US, Alabama, Tennessee

Patrick Dewayne Smith has spent two years rebuilding a life that a federal court once told him he could resume. He works two jobs, attends church with his family and has reconnected with relatives after serving 13 years of a life sentence for a nonviolent drug conviction. Now the Justice Department says a May Supreme Court ruling means his 2024 release is no longer legally valid.

The dispute, newly detailed by [The Associated Press](https://apnews.com/article/supreme-court-first-step-act-prison-sentences-c2b7ad8fd14e66978a5e57b1a32c6bf3?ref=theamericanquorum.com), turns one Tennessee case into a test of what happens when a high court decision changes the legal foundation for releases that judges already granted. Sentencing-reform group FAMM says Smith is among about a dozen people nationwide who could be sent back to federal prison. Their cases put the First Step Act’s promise of second chances against the legal principle that Congress chose not to make some reduced penalties retroactive.

## A life sentence built on earlier convictions

Smith was convicted in 2013 of participating in a drug conspiracy operating near the Tennessee-Alabama line and of money laundering. Four prior drug convictions allowed prosecutors to seek an enhanced penalty, and the trial judge imposed concurrent sentences of life for the drug count and 20 years for money laundering. The [court record](https://www.supremecourt.gov/DocketPDF/22/22-7303/263430/20230413132806093%5FAppendix%20bates.pdf?ref=theamericanquorum.com) shows that his case involved cocaine, crack cocaine and marijuana; it also shows that an earlier plea offer would have called for roughly 12 to 14 years.

Congress later reduced some mandatory penalties through the bipartisan [First Step Act](https://www.congress.gov/115/plaws/publ391/PLAW-115publ391.pdf?ref=theamericanquorum.com), signed in 2018\. The law also let incarcerated people ask courts directly for compassionate release after exhausting administrative steps, instead of depending entirely on the Bureau of Prisons to make the request. The governing [federal statute](https://uscode.house.gov/view.xhtml?req=%28title%3A18+section%3A3582%28c%29+edition%3Aprelim%29&ref=theamericanquorum.com) permits a reduction when “extraordinary and compelling reasons” warrant it and the sentencing factors support relief.

Smith initially lost a compassionate-release request. But after the U.S. Sentencing Commission updated its policy in 2023, he tried again. The commission said a court could consider a nonretroactive legal change when a person had served at least 10 years, was serving an unusually long sentence and faced a gross disparity between the old punishment and the likely current sentence. A federal judge applied that framework and released Smith in 2024.

## The Supreme Court closed the path used in his case

On May 28, the Supreme Court ruled 6–3 in [*Rutherford v. United States*](https://www.supremecourt.gov/opinions/25pdf/24-820%5F97be.pdf?ref=theamericanquorum.com) that the sentencing disparity created by Congress’s decision not to make lower penalties retroactive cannot itself qualify as an extraordinary and compelling reason for compassionate release. Justice Amy Coney Barrett wrote for the majority that the Sentencing Commission’s 2023 policy conflicted with the statute. Justice Sonia Sotomayor, joined by Justices Elena Kagan and Ketanji Brown Jackson, dissented and argued that the commission acted within the authority Congress gave it.

The decision resolved a long-running split among federal appeals courts. It did not erase compassionate release altogether: serious illness, advanced age, certain family emergencies and other qualifying circumstances remain potential grounds. But it invalidated the part of the commission’s policy that treated a change in sentencing law as the extraordinary reason, even when a prisoner had served a decade and the difference was substantial. [Reuters reported](https://www.reuters.com/legal/government/us-supreme-court-rejects-prison-sentence-reductions-under-reform-law-2026-05-28/?ref=theamericanquorum.com) that the ruling rejected claims by Daniel Rutherford and Johnnie Carter, whose mandatory terms would have been far shorter under current law.

## Why Smith may be returned to prison

Federal prosecutors argued in a September filing that the Supreme Court’s decision removes the central legal basis for Smith’s release. According to the AP account, the government says even current law would require at least 25 years, making the time-served reduction “difficult to justify.” A Justice Department official said the department cannot agree to a term below what the law requires.

That position does not mean Smith will be immediately taken into custody. The district court must address the government’s challenge, and the precise remedy is still being litigated. But the stakes are unusually high: his original life term remains on the books, while even the government’s current-law calculation would exceed the 13 years he served before release.

The case also highlights a structural limit of the First Step Act. Congress reduced certain penalties prospectively but did not automatically reopen every sentence imposed under the old rules. The Sentencing Commission tried to provide a narrow judicial review mechanism in [Amendment 814](https://www.ussc.gov/guidelines/amendment/814?ref=theamericanquorum.com); the Supreme Court held that mechanism could not override Congress’s choice on retroactivity. As a result, judges cannot use sentence disparity alone to preserve releases already granted on that rationale.

## Clemency and legislation are the remaining pressure valves

For Smith and similarly situated people, the most direct safeguard may now be presidential clemency. FAMM has urged the White House to keep all 12 affected people home, arguing that they have worked, reunited with families and complied with release conditions. The White House told AP that the administration is reviewing developments and remains proud of the First Step Act, but it has not announced a decision in Smith’s case.

Congress could also amend the law to make specified sentencing changes retroactive or explicitly authorize courts to consider them. Until then, courts must apply the Supreme Court’s interpretation, regardless of a defendant’s rehabilitation or the practical disruption of reincarceration.

Smith’s case therefore reaches beyond one man’s sentence. It asks whether a second chance already granted can survive after the legal rule supporting it disappears. The answer will determine whether Smith continues the life he has rebuilt in Alabama—or returns to federal custody years after a judge concluded that continued imprisonment was no longer warranted.