Christian N. Davis v. United States

In Davis v. United States, 124 F.4th 980 (5th Cir. 2025), the Fifth Circuit affirmed the district court’s decision to dismiss Davis’s motion for compassionate release for lack of jurisdiction. Davis is serving a military conviction imposed by a military court, so the district court had no jurisdiction to grant compassionate release.

Background: While in the army, Davis was convicted of several crimes, and he received a life sentence for his crimes. “As is typical with military courts, the court-martial dissolved after his case,” so he filed his compassionate-release motion in a federal district court.

Holding: Federal district courts lack jurisdiction to grant compassionate-release motions.

First, the compassionate-release statute, 18 U.S.C. § 3582, “does not apply to all prisoners.” Instead, it falls within Chapter 227 of Title 18, which applies to defendants found guilty of an offense under any federal statute “other than … the Uniform Code of Military Justice.” 18 U.S.C. § 3551(a). Because § 3582 does not say that it applies to military defendants, § 3551’s general prohibition applies.

Second, § 3582 directs that the sentencing court must determine whether to modify its original sentence. See § 3582(a) (referring to the court that “determine[d] the length of the [prison] term”). Because the federal district court did not impose Davis’s sentence, it lacked authority to modify that sentence.