Supreme Court News | Circuit Court Wins | Sentencing Commission Updates | BOP Halfway House Reversal --
Edition: Week of April 7–11, 2025
U.S. SUPREME COURT WATCH – Next Steps Ahead
The Supreme Court is back in action with its next conference scheduled for April 17, 2025. This week’s order list was short but included two
noteworthy cases that just made the cut for review next term:
Ellingburg v. United States –
Issue: Can the government impose restitution under the Mandatory Victim Restitution Act if it increases punishment in violation of the Constitution’s Ex Post Facto Clause?
Villarreal v. Texas –
Issue: Does it violate the Sixth Amendment right to counsel when a court bars a defendant and their lawyer from speaking about the defendant’s testimony during an overnight break?
➡ These cases may seem narrow but keep your eyes on them—small cracks in the wall can turn into big openings for future relief.
On Thursday, the Supreme Court issued an opinion on:
Noem v. Garcia, (No. 24A949), 604 U.S. (2025) – The U.S. Supreme Court ordered the Trump administration to facilitate the return of Kilmar Abrego Garcia, a Maryland resident who was
mistakenly deported to El Salvador despite a 2019 protection order. Abrego Garcia, who had a valid work permit and no criminal record, was deported on March 15 after being erroneously
arrested by ICE for suspected gang affiliation. The court upheld a district judge's order requiring the government to ensure his return and that his immigration proceedings resume as if he
had never been deported. While agreeing with the ruling, the justices asked for clarification on the judge’s authority, especially regarding foreign affairs. Liberal Justices criticized the
administration’s lack of legal basis for the deportation, highlighting that Abrego Garcia is a husband and father with strong U.S. ties and no criminal history. This case underscores the
judiciary's role in checking executive actions, especially concerning immigration enforcement and individual rights.
Rodriguez-Mendez v. United States, (No. 20-1360) (1st Cir. April 8, 2025)–Julio Rodríguez-Méndez scored a major victory after the First Circuit ruled that his robbery conviction under Article 173B doesn’t qualify as a violent felony under the Armed Career Criminal Act (“ACCA”). He had been hit with a harsh 216-month sentence under ACCA, but the court reversed and remanded for resentencing.
United States v. Maldonaldo-Maldonaldo, (No. 22-1650)(1st Cir. April 11, 2025)– In this sentencing appeal, the government forthrightly concedes that it breached its plea agreement with Héctor Maldonado-Maldonado ("Maldonado"). The government breached his plea agreement by: (1) by advocating for a four-point sentencing enhancement for "serious bodily injury" when the plea agreement expressly contemplated only a two-point enhancement for "bodily injury"; (2) by "tacitly push[ing]" for the application of the aggravated assault guideline, given that the four-point "serious bodily injury" enhancement and the other enhancements recommended in the PSR were available only if that guideline applied; (3) by failing to affirmatively request an 18-24 month sentence; and (4) by failing to object to the PSR's recommended sentence. The Court vacated Maldonado's sentence and remanded for expedited resentencing before a different district court judge.
U. S. SENTENCING COMMISSION UNANIMOUSLY APPROVES SIGNIFICANT AMENDMENTS TO FEDERAL SENTENCING GUIDELINES--At a public meeting held this afternoon, the United States Sentencing Commission (USSC) voted unanimously to adopt a sweeping set of amendments to the federal sentencing guidelines. These changes mark one of the most significant updates to the Guidelines Manual in years and reflect the Commission’s ongoing efforts to modernize and streamline federal sentencing.
Key Highlights:
Guideline Simplification: A major focus of the amendment package is the long-anticipated simplification of the guidelines. This includes the removal of numerous “departure” provisions that
have largely fallen into disuse since the Supreme Court’s decision in *Booker* (2005), which rendered the guidelines advisory rather than mandatory.
Supervised Release Reform: New provisions encourage a more individualized and evidence-based approach to the imposition and management of supervised release, potentially impacting a broad swath of federal cases.
Substantive Reforms to Drug and Firearm Offenses: The amendments address emerging issues such as fentanyl-laced counterfeit pills, aiming for more tailored sentences based on a defendant’s specific role in drug trafficking. Firearms provisions now include enhanced penalties for offenses involving machinegun conversion devices.
Resolution of Circuit Splits: The Commission has also taken steps to promote greater national consistency in sentencing by resolving several longstanding circuit conflicts.
Looking Ahead: The Commission has voted to conduct a retroactivity impact analysis for select drug and circuit conflict-related reforms, signaling
potential future opportunities for sentence reductions in qualifying cases.
While these amendments represent meaningful reform, they are not yet effective. Under the Sentencing Reform Act, Congress has a six-month window to review the changes. Unless Congress acts
to disapprove the amendments—a rare occurrence in the Commission’s 30+ year history—they will take effect on November 1, 2025.
More Information:
The Commission’s full press release and the preliminary amendment package—spanning 686 pages—are available on the USSC website. Notably, the most substantive changes are covered in the first
80 pages; the remainder primarily eliminates now-obsolete departure language from the Guidelines Manual.
We will continue to provide updates as further details and implementation guidance become available.
BREAKING: On March 31, 2025, the BOP proposed a new memo that would have capped halfway house placement under the Second Chance Act to just 60 days.
GOOD NEWS: That restriction has now been rescinded as of April 10, 2025. After public outcry and internal review, the Bureau will not limit SCA placement to 60 days—restoring hope for more meaningful pre-release transitions.
CASE LOOKUP PROGRAM – IS YOUR CONVICTION NOW CHALLENGEABLE?
President Trump’s recent Executive Order has reopened the door for relief under § 922(g) for those convicted of being a felon in possession of a firearm—especially if your prior was non-
violent and non-drug-related.
New rulings in the Third Circuit (Range, Daniels), Sixth, Eighth, and Ninth Circuits have already begun striking down gun laws that once seemed ironclad.
Courts in the First, Fourth, Ninth, and Tenth Circuits now allow sentencing judges to consider non-retroactive stacking reforms under § 403(a) as part of a compassionate release argument.
If this sounds like your situation, contact us ASAP. To request a lookup on this issue only, provide:
- Outside contact’s name and number
- Your court location
- Your case number
☎ Our team will notify your contact if we believe you qualify for any relief. Call us at (832) 346-0220 for more info.
For 30 years, our team has fought and won relief in cases involving:
- Direct appeals
- § 2255 and § 2241 petitions
- First Step Act motions
- Compassionate release
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Our WCEs are affordable, detailed, and focused on helping you get relief—whether you're just starting your case or years into your sentence. If you’re serious about fighting back, let’s get
started now.
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If you are serious about fighting your case and want us to evaluate your case to see if you may have relief coming, request a Written Case Evaluation.