Latest Updates
Federal Relief & Sentencing Developments — April 6–17, 2026
Supreme Court activity, federal sentencing developments, appellate reversals, guideline amendments, and federal relief considerations affecting post-conviction litigation.
Federal Sentencing Developments Overview
These federal sentencing developments may create new arguments in older federal cases involving sentencing calculations, appellate litigation, guideline amendments, suppression issues, and post-conviction relief considerations.
This federal relief update is provided for educational and informational purposes only. It is not legal advice and does not create legal representation.
Supreme Court Watch
Major Arguments Expected in Late April
The Supreme Court often hears major cases late in the term, with decisions expected before the term ends. The upcoming period includes important immigration-related cases and a major Fourth Amendment case involving modern digital surveillance.
Immigration-related cases may affect lawful permanent residents, TPS holders, and families where a federal conviction triggers immigration consequences.
Chatrie v. United States: Geofence Warrants
Chatrie v. United States, argued April 27, involves geofence warrants, which are broad location-data demands that often begin by collecting device-location information from a geographic area before narrowing to potential suspects.
Federal Relief Consideration: This case may affect suppression arguments in matters involving cellphone location data, Google location history, electronic surveillance, and broad digital warrants.
§ 922(g)(1) Watch: Nonviolent Felony Issues
The Supreme Court has not yet resolved whether 18 U.S.C. § 922(g)(1), the federal felon-in-possession statute, may be unconstitutional as applied to certain individuals with old or nonviolent felony convictions.
The Court has continued declining review in some § 922(g)(1) petitions while lower courts continue addressing as-applied challenges.
Federal Relief Consideration: If a § 922(g)(1) conviction rests on an old, nonviolent felony, the issue may depend heavily on the circuit, procedural posture, conviction history, and available case records.
Favorable Published Appellate Developments
First Circuit: Upward-Variance Sentence Vacated
In United States v. Nieves-Díaz, No. 24-1834, the First Circuit vacated the sentence and remanded because the district court did not adequately justify and individualize the upward variance under the § 3553(a) factors.
Federal Relief Consideration: Above-Guidelines sentences may raise reviewable issues when the sentencing court does not clearly explain why the higher sentence is justified based on the individual facts of the case.
First Circuit: Confrontation Clause Conviction Vacatur
In United States v. Cartagena, No. 23-1871, the First Circuit held that the government violated the Confrontation Clause by introducing a non-testifying victim’s statement through a medical expert when the victim was unavailable for cross-examination.
The court vacated the conviction on one count, affirmed the remaining counts, and remanded.
Federal Relief Consideration: Expert testimony may create confrontation issues when an expert repeats testimonial statements from a non-testifying witness and those statements help prove a disputed fact.
Second Circuit: § 924(c) and § 924(j) Double Conviction Issue
In United States v. Barrett, No. 21-1379, the Second Circuit addressed whether a defendant may remain convicted under both § 924(c) and § 924(j) for a single act that violates both provisions.
The court directed the district court to vacate one of the convictions and resentence consistently with applicable Supreme Court authority.
Federal Relief Consideration: Judgments involving both § 924(c) and § 924(j) tied to the same incident may require careful review for duplicative conviction or sentencing issues.
Fourth Circuit: Revocation Sentence Vacated
In United States v. Jones, No. 24-4624, the Fourth Circuit vacated a supervised-release revocation sentence after finding that the district court treated a drug-testing violation as the wrong grade, which affected the advisory Guidelines range.
Federal Relief Consideration: Supervised-release revocation sentences may be vulnerable when the violation grade, advisory range, or sentencing calculation was incorrect.
Ninth Circuit: Obstruction Enhancement Requires Specific Findings
In United States v. Williams, No. 24-5792, the Ninth Circuit affirmed the conviction but vacated the sentence because the district court applied an obstruction-of-justice enhancement without making the required specific findings.
Federal Relief Consideration: Obstruction or perjury enhancements may require specific findings on the record. If the sentencing court failed to make those findings, the enhancement may deserve review.
Tenth Circuit: Sentence Vacated for Sentencing Error
In United States v. Thompson, No. 25-3019, the Tenth Circuit vacated the sentence and remanded for resentencing after finding error in how the district court justified the sentence.
Federal Relief Consideration: Even when convictions remain intact, sentencing errors may still create meaningful resentencing opportunities.
Fast Screening Considerations
A case-specific review may be especially important where any of the following issues appear in the record:
- § 924(c) and § 924(j) convictions arising from the same incident
- § 922(g)(1) based on an old or nonviolent felony
- Sentencing ranges driven by methamphetamine purity, “actual,” or “ice” calculations
- Sophisticated-means enhancements or major loss-table increases
- Career offender or ACCA predicate issues
- Supervised-release revocation grade or Guidelines range concerns
Sentencing Commission Update
On April 16, the U.S. Sentencing Commission voted unanimously to promulgate a package of guideline amendments described as “good government” amendments intended to simplify and streamline federal sentencing.
The adopted package is scheduled to take effect November 1, 2026, unless blocked by Congress.
Highlights of the Adopted Amendments
- Clarifies sentencing options involving probation, fines, and imprisonment
- Updates economic crime guidelines to account for inflation
- Streamlines treatment of multiple counts to promote more consistent sentencing
- Eliminates more than two dozen rarely or never-used specific offense characteristics
- Implements guideline treatment related to the HALT Fentanyl Act
Important Retroactivity Warning
Retroactivity is not automatic. Even if guideline amendments take effect, they do not automatically help individuals already sentenced unless the Sentencing Commission separately votes to make the amendments retroactive.
Federal Relief Consideration: Cases involving loss-table calculations, multiple-count grouping, drug guideline calculations, or guideline add-ons may deserve organized review to identify sentence drivers and preserve possible future arguments.