COLLATERAL STUMBLING BLOCKS: HOW HABEAS CORPUS AND THE AEDPA HAVE CREATED IMMOVABLE IMPEDIMENTS TO COLLATERAL RELIEF UNDER THE FIRST STEP ACT FOR FEDERAL INMATES SENTENCED IN VIOLATION OF THE LAW.

The article examines how habeas corpus procedures and the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) have created significant legal barriers that prevent federal inmates sentenced unlawfully from obtaining collateral relief through compassionate release under the First Step Act of 2018. It focuses on the case of Roy West, who was sentenced to life imprisonment in violation of the law but was denied relief due to courts treating compassionate release motions as equivalent to second or successive habeas petitions barred by AEDPA. While the First Step Act amended 18 U.S.C. § 3582(c)(1)(A) to allow inmates to file compassionate release motions directly, most circuit courts have held that sentencing errors do not constitute “extraordinary and compelling” reasons for release and that habeas corpus motions under 28 U.S.C. § 2255 remain the exclusive remedy for challenging sentence legality. The article highlights a circuit split, noting that the First Circuit has allowed compassionate release for sentencing errors under a broader interpretation, but other circuits have rejected this. It argues that compassionate release is a distinct collateral relief mechanism from habeas corpus, supported by statutory differences and recent rulings on Federal Rule of Civil Procedure 60(b) motions, and suggests that judicial discretion and legislative clarification are needed to enable inmates like West to obtain relief for unlawful sentences through compassionate release. [Extracted from the article]