United States v. Jonathan Wright
Split Score
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Case Summary
Disposition
Vacated
The Eighth Circuit considered whether President Biden’s 2025 commutation of Jonathan Wright’s sentence rendered Wright’s pending § 3582(c)(1)(A) appeal moot and, if not, whether the district court abused its discretion in resentencing him. The court held that a presidential commutation does not moot judicial review of the underlying sentence and that the district court abused its discretion by refusing to consider that Wright’s Arkansas drug convictions no longer qualify as predicate offenses; it therefore vacated the sentence and remanded for resentencing.
Circuit Split Identified
Legal Issue
Whether a federal court retains authority to modify a criminal sentence after the President has commuted that sentence, or whether any further judicial modification is barred (thereby mooting the prisoner’s appeal).
Circuit Positions
A presidential commutation bars courts from further reducing or modifying the sentence; appeals are moot.
A commutation only alters the sentence’s execution; courts retain jurisdiction and may further modify the judgment.
Conflict Summary
The Fourth Circuit has held that a presidential commutation transforms the sentence into an executive act that courts may not disturb, rendering any request for further judicial relief moot. The Sixth Circuit (joined by the Eighth Circuit in this case) concludes that a commutation merely limits the sentence’s execution and leaves the underlying judicial judgment intact, so courts may still reduce or otherwise modify the sentence; the Fifth and Eleventh Circuits have treated such appeals as live without squarely deciding the separation-of-powers question, effectively allowing judicial modification.