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The Sixth Circuit Courthouse, Pictured here, has made several
The Sixth Circuit and Non-Retroactive FIRST STEP Act Considerations for 3582 Motions

Over the past few months we have covered several cases where the appellate courts have stated that extraordinary and compelling circumstances are not bound to the text of 1B1.13. This has ended up meaning that almost anything can be an extraordinary and compelling circumstance in most circuits. But the Sixth Circuit has made several holdings that call into question non-retroactive provisions of the FIRST STEP Act that many incarcerated persons have been using to get relief.

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