Syllabus

Title 18 U. S. C. § 3582(c)(1)(A)(i) authorizes a district court, on motion of the Director of the Bureau of Prisons or — after the First Step Act of 2018 — on motion of the defendant, to "reduce the term of imprisonment . . . after considering the factors set forth in section 3553(a) to the extent that they are applicable, if it finds that . . . extraordinary and compelling reasons warrant such a reduction" and the reduction "is consistent with applicable policy statements issued by the Sentencing Commission." The Commission's organic statute directs it to "describe what should be considered extraordinary and compelling reasons for sentence reduction" and provides that "[r]ehabilitation of the defendant alone shall not be considered an extraordinary and compelling reason." 28 U. S. C. § 994(t). A separate statute, 28 U. S. C. § 2255, authorizes a federal prisoner to "move the court which imposed the sentence to vacate, set aside or correct the sentence" on the ground that the sentence "was imposed in violation of the Constitution or laws of the United States," that the court was "without jurisdiction," that the sentence "was in excess of the maximum authorized by law," or that the sentence "is otherwise subject to collateral attack." § 2255(a). A successful § 2255 motion produces vacatur; § 3582(b) provides that a "judgment of conviction" that includes a sentence subject to modification under § 3582(c) "constitutes a final judgment for all other purposes."

In 2000 Patrick Darge was hired to kill two cartel members who had come to New York to collect a $6.5 million debt. The evidence at trial established that Darge recruited petitioner Joe Fernandez as a backup shooter. Fernandez was convicted in 2013 of conspiracy to commit murder for hire resulting in death, 18 U. S. C. § 1958, and of using a firearm in furtherance of a crime of violence causing death, § 924(j). He was sentenced to a mandatory life term on the first count and a consecutive non-mandatory life term on the second. His cooperating co-defendants received sentences ranging from 2 to 30 years. His first § 2255 motion, which asserted actual innocence, was denied as "plainly meritless." J. A. 99–105. His second § 2255 motion succeeded in vacating the § 924(j) conviction under United States v. Davis, 588 U. S. 445 (2019). The mandatory life sentence on Count One remained.

In 2021 Fernandez filed a motion under § 3582(c)(1)(A)(i). The district judge — the same judge who had presided over the trial, the post-trial motions, the original sentencing, and the § 2255 proceedings — granted the motion and reduced the sentence to time served. The judge identified six reasons supporting "a certain disquiet" about the verdict, including the credibility of the cooperating witness, the government's choice not to charge the getaway driver for the murders, and a sentencing disparity between Fernandez and the principal that the court found "extraordinary." Pet. App. 28a–39a. The court was explicit that it was not vacating the verdict: "The jury verdict is not being vacated or declared an improper verdict." Pet. App. 37a.

The Second Circuit reversed. 104 F. 4th 420 (2024). The panel held that "[a] potential-innocence claim challenges the validity of the underlying conviction, and a sentencing disparity claim challenges the validity of the sentence imposed," and that "the validity of a conviction or sentence can be challenged only on direct appeal or collateral review, which have specifically calibrated procedural limitations." Pet. App. 13a. The court reasoned that § 2255 is "more specific in scope than § 3582(c)(1)(A)" because it "places explicit restrictions on the timing of a habeas petition and the permissibility of serial petitions," Pet. App. 19a; that compassionate release was, in the court's words, neither a channel to habeas relief nor an end-run around § 2255's limitations, ibid.; and that "[n]o matter how an inmate characterizes his request for relief, the substance of that request controls," Pet. App. 26a (quoting United States v. Ferguson, 55 F. 4th 262, 270 (4th Cir. 2022)). This Court granted certiorari to consider whether "a combination of 'extraordinary and compelling reasons' that may warrant a discretionary sentence reduction under 18 U. S. C. § 3582(c)(1)(A) can include reasons that may also be alleged as grounds for vacatur of a sentence under 28 U. S. C. § 2255." 145 S. Ct. 2731.

Held:

1. Section 3582(c)(1)(A)(i) does not contain an unwritten categorical exclusion of reasons that may also be alleged as grounds for vacatur under § 2255. Pp. 4–14.

   (a) The phrase "extraordinary and compelling reasons" describes a threshold of intensity, not a class of permissible subjects. Both parties accept that "extraordinary" carries its ordinary 1984 meaning — "most unusual," "far from common," "having little or no precedent" — and that "compelling" means "forcing, impelling, driving." Those are terms of degree. They do their own work. They do not require, and Congress's chosen text does not supply, the further restriction the Court of Appeals read into the statute. Pp. 5–7.

   (b) The single substantive limit Congress placed on the universe of cognizable "reasons" is the directive in 28 U. S. C. § 994(t) that "[r]ehabilitation of the defendant alone shall not be considered an extraordinary and compelling reason." That bar is express and is the only one of its kind in the statute. The negative implication of an express limit is that other limits were not enacted. The bar is also instructive in another respect: its operative word is "alone." Congress did not foreclose consideration of rehabilitation in combination with other reasons. It declined, by parallel reasoning, to foreclose other categories of reasons in combination either. Pp. 7–9.

   (c) The background tradition of federal sentencing reinforces the textual reading. From Williams v. New York, 337 U. S. 241, 246–247 (1949), through Pepper v. United States, 562 U. S. 476, 489 (2011), this Court has recognized that "[h]ighly relevant — if not essential — to [a judge's] selection of an appropriate sentence is the possession of the fullest information possible concerning the defendant's life and characteristics." Concepcion v. United States, 597 U. S. 481, 491 (2022), restated the principle for sentence-modification proceedings: "the only limitations on a court's discretion to consider relevant materials at an initial sentencing or in modifying that sentence are those set forth by Congress in a statute or by the Constitution." And Kimbrough v. United States, 552 U. S. 85, 103 (2007), supplied the interpretive consequence: "Drawing meaning from silence is particularly inappropriate" in the sentencing context. Pp. 9–11.

   (d) The general/specific canon of RadLAX Gateway Hotel, LLC v. Amalgamated Bank, 566 U. S. 639 (2012), does not displace this reading. That canon resolves "irreconcilable conflict." There is no irreconcilable conflict between § 3582(c)(1)(A)(i) and § 2255. The two statutes provide different relief on different showings; they leave each "some distinct cases." J. E. M. Ag Supply, Inc. v. Pioneer Hi-Bred Int'l, Inc., 534 U. S. 124, 144 (2001). Pp. 11–13.

   (e) The habeas-channeling line is not to the contrary. The operative formulation is the one set out in Heck v. Humphrey, 512 U. S. 477, 487 (1994): an action falls within the channeling rule only "if . . . a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence." Section 3582(b) provides that a judgment of conviction modified under § 3582(c) "constitutes a final judgment for all other purposes." A § 3582 grant therefore does not necessarily imply invalidity; it presupposes the judgment's continuing validity and modifies only the term of imprisonment. Wilkinson v. Dotson, 544 U. S. 74, 81–82 (2005), confirms the literal test. Pp. 13–14.

2. The Court declines to adopt the alternative formulation offered by the United States at oral argument — that the relevant exclusion reaches every "asserted reason that attacks the validity of the conviction or sentence," Tr. of Oral Arg. 75 — for two reasons. First, the formulation differs in substance from the one urged in the United States' brief, and was acknowledged by the Government at argument to be a different rule. Ibid. Second, the "attacks the validity" formulation would require this Court to decide whether claims of freestanding actual innocence are cognizable under § 2255 — a question this Court has previously avoided. See Herrera v. Collins, 506 U. S. 390, 400 (1993); McQuiggin v. Perkins, 569 U. S. 383, 392 (2013). We do not resolve that question on a record built around a different rule. Pp. 14–17.

3. The institutional allocation Congress chose is preserved. Section 994(t) directs the Sentencing Commission to "describe what should be considered extraordinary and compelling reasons for sentence reduction." A court of appeals "may not categorically proscribe the consideration of" a factor that the Commission has not itself excluded. Koon v. United States, 518 U. S. 81, 106 (1996). Loper Bright Enterprises v. Raimondo, 603 U. S. 369, 412 (2024), preserves that allocation: "when a particular statute delegates authority to an agency consistent with constitutional limits, courts must respect the delegation, while ensuring that the agency acts within it." We express no view on whether the Commission may, consistent with the statute, identify § 2255-overlapping reasons as a category outside § 3582(c)(1)(A)(i)'s scope. Pp. 17–19.

4. The judgment is reversed and the case is remanded. We do not decide whether the considerations the District Court relied on, taken in combination, are "extraordinary and compelling" within the meaning of § 3582(c)(1)(A)(i). That question is for the Court of Appeals in the first instance, applying the standard set forth today. Pp. 19–20.

The judgment of the United States Court of Appeals for the Second Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.

Opinion of the Court

Section 3582(c)(1)(A)(i) of Title 18 authorizes a district court to "reduce the term of imprisonment . . . after considering the factors set forth in section 3553(a) to the extent that they are applicable, if it finds that . . . extraordinary and compelling reasons warrant such a reduction" and the reduction "is consistent with applicable policy statements issued by the Sentencing Commission." The Sentencing Reform Act of 1984 enacted that provision. The First Step Act of 2018, § 603(b), 132 Stat. 5239, amended it to permit prisoners to file directly after exhausting administrative remedies or after a 30-day lapse from a warden's receipt of the request.

The question presented is whether a court asked to find "extraordinary and compelling reasons" may consider a reason that could also be alleged as a ground for vacatur of the sentence under 28 U. S. C. § 2255. The Court of Appeals for the Second Circuit answered no. It held that any reason of that character is reserved exclusively to § 2255 — which has its own statute of limitations, second-or-successive bar, and certificate-of-appealability requirement — and that § 3582(c)(1)(A)(i) supplies no parallel avenue. We hold otherwise. The text of § 3582(c)(1)(A)(i) imposes one categorical limit on what may qualify as "extraordinary and compelling reasons" — the rehabilitation-alone bar in 28 U. S. C. § 994(t) — and the habeas-channeling rule supplies no additional unwritten limit so long as the requested relief does not necessarily imply the invalidity of the conviction or sentence. The judgment of the Court of Appeals is reversed and the case is remanded.

I

We begin with the facts and procedural history.

Patrick Darge was hired in February 2000 to kill two members of a Mexican drug-trafficking organization who had come to New York City to collect a $6.5 million debt for cocaine. Trial evidence established that Darge recruited petitioner Joe Fernandez as a backup shooter and recruited Luis Rivera as the getaway driver. The two victims were lured into a Bronx apartment-building lobby. Darge fired the first shots and, when his gun jammed, the trial evidence indicated that Fernandez fired fourteen additional rounds. Pet. App. 4a; Resp. Br. 8–9. Fernandez was arrested in 2011 and, after maintaining his innocence and going to trial, was convicted in 2013 of conspiracy to commit murder for hire resulting in death, 18 U. S. C. § 1958, and of using a firearm in furtherance of a crime of violence causing death, § 924(j). Darge, who cooperated, received 30 years. Reyes received 25. Minaya, the trafficker who arranged the contract, received 15. Rivera received 2 years on an unrelated narcotics charge. Pet. App. 7a.

Fernandez was sentenced by Judge Hellerstein of the United States District Court for the Southern District of New York to a mandatory life term on the conspiracy count and a consecutive non-mandatory life term on the firearm count. The Court of Appeals affirmed the convictions on direct appeal. United States v. Fernandez, 648 F. App'x 56 (2d Cir. 2016).

Fernandez then filed two motions under 28 U. S. C. § 2255. The first asserted, among other things, actual innocence. The District Court denied the motion, ruling that the actual-innocence assertion was "not . . . an extraordinary case" within Schlup v. Delo, 513 U. S. 298 (1995). J. A. 94–95. The Second Circuit affirmed; this Court denied certiorari. The second § 2255 motion succeeded under United States v. Davis, 588 U. S. 445 (2019), in which we held the residual clause of § 924(c)(3)(B) unconstitutionally vague. The District Court vacated the § 924(j) conviction and the consecutive life term that accompanied it. The mandatory life sentence on Count One remained intact.

In 2021, Fernandez filed the motion now before us. He sought a reduction under § 3582(c)(1)(A)(i) on four grounds: (1) potential innocence in light of accumulated reasons to doubt the credibility of the cooperating witness Patrick Darge; (2) the disparity between his sentence and the substantially shorter sentences of his co-defendants; (3) COVID-19-related conditions of confinement; and (4) rehabilitation. Pet. App. 9a.

The District Court rejected the third ground and did not reach the fourth. It granted relief on the first and second. On the first, the court identified six considerations contributing to "a certain disquiet": the post-murder flight of the Darge brothers to the Dominican Republic, contrasted with Fernandez's eleven years of honest employment and family life in the United States; Darge's motive to lie and his history of lying to the government; inconsistencies in the ballistic evidence; the possibility that more effective cross-examination of Darge could have produced a different verdict; and the government's choice not to charge Rivera for participation in the murder scheme. Pet. App. 36a–37a. On the second, the court determined that the sentencing disparity between Fernandez and the cooperating principal was itself "extraordinary." Pet. App. 38a. The court emphasized that it was not disturbing the verdict: "Although there is factual support for the jury's verdict and the verdict has been affirmed, a certain disquiet remains." Pet. App. 36a. And: "The jury verdict is not being vacated or declared an improper verdict." Pet. App. 37a.

The Court of Appeals for the Second Circuit reversed. 104 F. 4th 420 (2024) (Sack, J., joined by Lohier and Kahn, JJ.). The panel reasoned that any reason that "challenges the validity" of a conviction or sentence is reserved exclusively to § 2255 and that, "[n]o matter how an inmate characterizes his request for relief, the substance of that request controls." Pet. App. 26a (quoting United States v. Ferguson, 55 F. 4th 262, 270 (4th Cir. 2022)). The Court of Appeals invoked the general/specific canon, treating § 2255 as the "more specific" statute, Pet. App. 19a, and observed that its conclusion accorded with the holdings of a "near-unanimous consensus" of sister circuits. Pet. App. 24a–25a. The lone outlier, the panel noted, was United States v. Trenkler, 47 F. 4th 42 (1st Cir. 2022). We granted certiorari. 145 S. Ct. 2731.

II

We begin with the text. Esquivel-Quintana v. Sessions, 581 U. S. 385, 391 (2017).

Section 3582(c)(1)(A)(i) authorizes a court to "reduce the term of imprisonment . . . if it finds that . . . extraordinary and compelling reasons warrant such a reduction" and that "such a reduction is consistent with applicable policy statements issued by the Sentencing Commission." 28 U. S. C. § 994(t), in turn, directs the Commission to "describe what should be considered extraordinary and compelling reasons for sentence reduction, including the criteria to be applied and a list of specific examples," and adds: "Rehabilitation of the defendant alone shall not be considered an extraordinary and compelling reason."

Two textual features control. The first is the phrase "extraordinary and compelling reasons." The second is § 994(t)'s express limit.

A

The parties agree on the dictionary definitions Congress used in 1984. "Extraordinary" carries its ordinary meaning of "most unusual," "far from common," or "having little or no precedent." "Compelling" means "forcing, impelling, driving." Both definitions describe intensity. They name a threshold a "reason" must clear, not a class of reasons from which the eligible set is drawn. A reason can be "extraordinary" or "compelling" — or fail to be — without regard to which category of explanation it belongs to.

The Government's reading conscripts the same words to do different work. On the Government's account, "extraordinary" and "compelling" do not merely describe the intensity of a reason; they categorically exclude reasons of a certain kind. The kind excluded, on the Government's brief, comprises reasons that could be raised under § 2255. The kind excluded, on the Government's formulation at oral argument, comprises reasons that "attack[] the validity of the conviction or sentence." Tr. of Oral Arg. 75. Whichever formulation is adopted, the move requires "extraordinary" and "compelling" to bear a category-defining function the dictionary definitions do not supply.

We are not persuaded. The dictionary definitions Congress drew on do their own work, and they do enough of it. A claim that a court must "find[]" "extraordinary and compelling reasons" before granting relief is a stringent requirement. The Sentencing Commission's data confirm the point: in fiscal year 2024, district courts granted approximately 430 motions under § 3582(c)(1)(A) out of roughly 158,000 federal prisoners — under three-tenths of one percent. Pet. Br. 33 & n. 3. Whatever else may be said about that empirical record, it is not the record of a threshold that has been read out of the statute.

If Congress wished to add a categorical limit beyond intensity, it knew how. The Sentencing Reform Act and § 994(t) supply the proof. In § 994(t), Congress identified one — and only one — substantive category of reason that may not, alone, support a finding of "extraordinary and compelling reasons": "[r]ehabilitation of the defendant alone." Congress wrote no other substantive exclusion. It identified no other category. The negative implication of an express limit is that other limits were not enacted. See Esteras v. United States, 145 S. Ct. 2031, 2040 (2025); Lomax v. Ortiz-Marquez, 590 U. S. 595, 600 (2020) ("A court may not narrow a provision's reach by inserting words Congress chose to omit.").

That § 994(t) excluded rehabilitation alone is instructive in a second respect as well. The operative word is "alone." Congress did not foreclose consideration of rehabilitation in combination with other reasons. The Government acknowledges, as it must, that rehabilitation may figure as one factor among several in the "extraordinary and compelling" calculus. The same negative implication applies to the broader question this case presents: an enacted bar on the use of one category "alone" does not authorize a court to enact further unwritten bars on the combination use of others.

B

The background tradition of federal sentencing reinforces this reading. From Williams v. New York, 337 U. S. 241, 246–247 (1949), through United States v. Tucker, 404 U. S. 443, 446 (1972), and Pepper v. United States, 562 U. S. 476, 489 (2011), this Court has recognized that sentencing courts may consider "the widest possible breadth of information about a defendant." Section 3661 of Title 18 codifies the same proposition: "No limitation shall be placed on the information concerning the background, character, and conduct of a person convicted of an offense which a court of the United States may receive and consider for the purpose of imposing an appropriate sentence."

That background tradition extends to sentence-modification proceedings. Concepcion v. United States, 597 U. S. 481, 491 (2022), described the proposition directly: "the only limitations on a court's discretion to consider relevant materials at an initial sentencing or in modifying that sentence are those set forth by Congress in a statute or by the Constitution." And the interpretive consequence is set out in the same case, quoting Kimbrough v. United States, 552 U. S. 85, 103 (2007): "Drawing meaning from silence is particularly inappropriate" in the sentencing context, "for Congress has shown that it knows how to direct sentencing practices in express terms."

The Government answers that Concepcion's holding addressed the § 3553(a) calibration step rather than the § 3582(c)(1)(A)(i) eligibility step, and that the "only limitations" framework is therefore inapplicable to the threshold inquiry. Resp. Br. 42–43. The Government further notes a sentence in Concepcion's opinion observing that § 3582(c)(1)(A) "expressly cabin[s]" district courts' discretion by requiring consistency with Commission policy statements. 597 U. S., at 494. We do not read either point to displace our analysis. The "only limitations" framework is not a holding about a single calibration step; it is a description of the structural relationship between sentencing-modification authority and unwritten judicial limitations. The provision Concepcion characterized as "expressly cabin[ed]" is § 3582(c)(1)(A)(i)'s policy-statement requirement, not an unwritten kind-limit on the threshold inquiry. The express cabin is the one Congress wrote; Concepcion's point was not that we should read in another.

C

The Court of Appeals invoked the general/specific canon of RadLAX Gateway Hotel, LLC v. Amalgamated Bank, 566 U. S. 639 (2012). The canon resolves "irreconcilable conflict[s]" between two provisions of the same statute or between two statutes whose terms cannot coexist. Id., at 645. Where two provisions can coexist, the canon does not apply. We have "not hesitated to give effect to two statutes that overlap, so long as each reaches some distinct cases." J. E. M. Ag Supply, Inc. v. Pioneer Hi-Bred Int'l, Inc., 534 U. S. 124, 144 (2001).

Section 3582(c)(1)(A)(i) and § 2255 are not in irreconcilable conflict. They occupy different statutory work. Section 2255 supplies a mandatory vacatur remedy on a showing that the sentence "was imposed in violation of the Constitution or laws of the United States," § 2255(a), with extensive procedural calibrations supplied by AEDPA — a one-year statute of limitations, § 2255(f), a second-or-successive bar, § 2255(h), and a certificate-of-appealability requirement, 28 U. S. C. § 2253(c). Section 3582(c)(1)(A)(i), by contrast, supplies discretionary modification authority for "extraordinary and compelling reasons," directs the court to consider the § 3553(a) factors "to the extent that they are applicable," requires consistency with the Commission's policy statements, and produces a more limited remedy — modification, not vacatur. Each statute reaches cases the other does not. Section 2255 reaches a defendant whose sentence is legally infirm and who can meet the substantive and procedural conditions Congress imposed. Section 3582(c)(1)(A)(i) reaches a defendant whose circumstances meet a high discretionary threshold and whose case has, after a § 3553(a) reweighing, become an appropriate one for sentence reduction. The two are different statutes with different requirements; the general/specific canon does not bridge them by judicial fiat.

D

The habeas-channeling line is the Government's strongest argument and merits separate treatment.

The channeling line begins with Preiser v. Rodriguez, 411 U. S. 475 (1973), which held that a state prisoner's claim seeking immediate or speedier release lies within the "core of habeas corpus" and may not be brought under § 1983. Preiser's controlling principle is that a prisoner cannot "evade this requirement by the simple expedient of putting a different label on their pleadings." Id., at 489–490. The principle is sound. It is also bounded. Preiser did not establish a freestanding rule that any claim with conceivable overlap to habeas must be channeled into habeas regardless of the relief sought.

The operative test was supplied two decades later in Heck v. Humphrey, 512 U. S. 477 (1994). Heck held that a § 1983 damages claim is barred "if . . . a judgment in favor of the plaintiff would necessarily imply the invalidity of his conviction or sentence." Id., at 487. The opposite proposition follows directly: if a judgment in favor of the plaintiff would not necessarily imply invalidity, "the action should be allowed to proceed, in the absence of some other bar." Ibid. The word "necessarily" is doing the work. It distinguishes claims whose success would as a matter of law require treating the conviction as void from claims whose success can coexist with the conviction.

Wilkinson v. Dotson, 544 U. S. 74 (2005), confirmed the test. There the Court permitted state prisoners to challenge parole procedures under § 1983 because success "will not 'necessarily demonstrate the invalidity of confinement or its duration.'" Id., at 82. Skinner v. Switzer, 562 U. S. 521, 534 (2011), permitted a DNA-testing claim to proceed for the same reason.

The Government urges that the habeas-channeling line is broader than its literal test, and that Jones v. Hendrix, 599 U. S. 465 (2023), supplies the modern formulation. Jones held that 28 U. S. C. § 2255(e)'s saving clause does not permit a federal prisoner to bring a successive § 2241 petition where § 2255(h) forecloses successive § 2255 relief. The Government reads Jones as a general anti-evasion command. We read it more narrowly. Jones turned on the relationship between two subsections of § 2255 itself. The opinion's structural insistence was that those subsections must be construed "in harmony, not set them at cross-purposes." Id., at 478. Whether § 3582(c)(1)(A)(i) and § 2255 are at cross-purposes depends on whether they can be read in harmony — and we have explained that they can.

Section 3582(b) is dispositive of the channeling question. It provides that, "[n]otwithstanding the fact that a sentence to imprisonment can subsequently be . . . modified pursuant to the provisions of subsection (c)," "a judgment of conviction that includes such a sentence constitutes a final judgment for all other purposes." A § 3582 grant therefore does not "necessarily imply" the invalidity of the conviction; it presupposes the conviction's continuing validity and modifies only the term of imprisonment. That is precisely the posture the District Court occupied here when it stated that "[t]he jury verdict is not being vacated or declared an improper verdict." Pet. App. 37a. The contrast with vacatur is structurally explicit. As we explained last Term in Hewitt v. United States, 606 U. S. ___ (2025), "vacated court orders are void ab initio and thus lack any prospective legal effect." 606 U. S., at ___ (slip op., at 10). A § 3582 modification does the opposite: it leaves the prior judgment in place and reduces only the sentence. The channeling rule, as articulated in Heck and Wilkinson, does not reach that posture.

III

We turn to the Government's alternative formulation, offered at oral argument. Pressed by the Court to articulate a workable rule, the Solicitor General's deputy proposed that the relevant exclusion reach not only claims that "could be raised under § 2255" but every "asserted reason that attacks the validity of the conviction or sentence." Tr. of Oral Arg. 75; see also id., at 79–80. The Government acknowledged that this formulation differs from the one its brief had advanced. Id., at 75 ("[T]here — there is a real difference between that formulation and the one you most often give in your brief.").

We do not adopt the at-argument formulation, for two reasons.

First, an opinion of this Court ordinarily resolves the question on the rule a party has placed in its written submissions, not on a rule reformulated under questioning. The "attacks the validity" formulation was the one the Government articulated to the Court in real time; it had not been pressed below, was not the one the Second Circuit applied, and was not the principal one advanced in the briefs. See Pet. App. 13a (Second Circuit articulating the rule as encompassing claims that "could be raised on direct appeal or in a habeas proceeding"). A rule reformulated on the day of argument is not a rule on which the lower courts can be said to have ruled, the parties can be said to have briefed, or the amici can be said to have responded.

Second, the "attacks the validity" formulation would require resolving a question this Court has previously chosen not to resolve: whether a freestanding claim of actual innocence is cognizable under § 2255 at all. In Herrera v. Collins, 506 U. S. 390 (1993), we observed that "[c]laims of actual innocence based on newly discovered evidence have never been held to state a ground for federal habeas relief absent an independent constitutional violation occurring in the underlying state criminal proceeding." Id., at 400. McQuiggin v. Perkins, 569 U. S. 383, 392 (2013), treated actual innocence as a "gateway" through procedural default, not as a freestanding habeas ground. As the colloquy at oral argument made plain, neither the Government's brief formulation ("cognizable under § 2255") nor the at-argument formulation ("attacks the validity of the conviction") supplies an answer to the case as it actually arises here, because Fernandez's claim of potential innocence is, by all accounts, not cognizable under § 2255 in its current posture. Tr. of Oral Arg. 33, 74, 78. We will not decide the Herrera question on a record assembled around a different rule, in order to make a different rule operative.

What remains is the rule we articulated in Part II: a reason that might also serve as the predicate for a § 2255 motion is not, for that reason, categorically excluded from the "extraordinary and compelling reasons" inquiry. The reason must satisfy § 3582(c)(1)(A)(i)'s threshold; the requested relief must remain modification, not vacatur; and the basis for relief, even if related to events at trial, must not necessarily imply that the conviction itself is invalid. Where those conditions are met, the channeling rule of Preiser and its progeny does not apply.

IV

Two further matters.

A

The rehabilitation-alone analogue figured prominently in the parties' arguments and at oral argument. We make explicit what is implicit in Part II.

Congress's express decision in § 994(t) to bar rehabilitation as a sole basis for relief — while permitting rehabilitation to figure among other reasons — describes the structure of the eligibility step. Reasons are aggregated. A particular reason may not, standing alone, suffice; together with others, it may. The "extraordinary and compelling" finding is made on the combined record. The Sentencing Commission's current policy statement, U. S. S. G. § 1B1.13 (Nov. 1, 2023), reflects that structure: it identifies several categories of qualifying reasons and provides that a court may also consider "any other circumstance or combination of circumstances . . . similar in gravity to those described in paragraphs (1) through (4)." § 1B1.13(b)(5).

A reason that may also be alleged as a § 2255 ground is one among the many a court may, in an appropriate case, consider. We do not hold that such a reason, standing alone, can support a finding of "extraordinary and compelling reasons." Just as with rehabilitation, the question whether it can do so independently is a question we need not resolve to decide this case. See Pt. V, infra. What the rehabilitation-alone analogue does establish is that the combination inquiry the rephrased question presented poses is the right one. A § 2255-overlapping reason may figure as one factor among several. The threshold "extraordinary and compelling" question is the demanding one. It is asked across the combined record.

B

The case also bears on the allocation of policymaking authority between courts and the Sentencing Commission.

Section 994(t) directs the Commission to "describe what should be considered extraordinary and compelling reasons for sentence reduction, including the criteria to be applied and a list of specific examples." That delegation is to the Commission, not to the courts of appeals. As Koon v. United States, 518 U. S. 81, 106 (1996), made plain in the context of departure authority, an appellate decision that "categorically proscribe[s]" the consideration of a factor "transgress[es] the policymaking authority vested in the Commission." A court of appeals may not declare that a class of reasons can never qualify when neither the text nor the Commission has so declared. See also Pepper, 562 U. S., at 491.

Loper Bright Enterprises v. Raimondo, 603 U. S. 369 (2024), preserves the allocation. Although Loper Bright held that courts must "exercise their independent judgment in deciding whether an agency has acted within its statutory authority," it expressly reaffirmed that, "when a particular statute delegates authority to an agency consistent with constitutional limits, courts must respect the delegation, while ensuring that the agency acts within it." Id., at 412. The § 994(t) delegation is one Congress made expressly. Loper Bright respects it.

The United States proposed at oral argument that, "in a post-Loper Bright world," the Commission may lack authority to extend "extraordinary and compelling" to encompass § 2255-overlapping reasons. Tr. of Oral Arg. 56. We express no view on the question. Whether the Commission may, by policy statement, identify § 2255-overlapping reasons as a categorical exclusion is a question for the Commission to consider in the first instance and for this Court if it is later presented. What we hold today is that the courts of appeals may not impose such an exclusion in advance of any Commission action and on no authority other than their reading of "extraordinary and compelling."

V

We do not decide whether the considerations the District Court relied on, taken in combination, are "extraordinary and compelling" within the meaning of § 3582(c)(1)(A)(i). The Court of Appeals did not reach that question; its disposition rested on its categorical reading of the statute. With that categorical reading set aside, the Court of Appeals will be in a position to address, in the first instance, whether the combination of reasons the District Court relied on suffices on the merits. We note three points the Court of Appeals will be well positioned to address.

First, the Court of Appeals may consider whether the sentencing-disparity rationale, standing alone, is "extraordinary" — or, instead, whether a disparity attributable to a co-defendant's decision to cooperate "should be expected." Pet. App. 16a (citing Missouri v. Frye, 566 U. S. 134, 143–144 (2012)).

Second, the Court of Appeals may consider whether the "disquiet" rationale — premised on a sentencing judge's accumulated doubts about the credibility of a cooperating witness, untethered to any new fact or law not available at trial — can, standing alone or in combination, suffice. Several Justices pressed petitioner's counsel on whether disquiet about a jury verdict is properly an "individual circumstance" within the meaning of "extraordinary and compelling," Tr. of Oral Arg. 35–36, 38–40. We do not answer that question today, but it is a substantial one and is presented squarely on remand.

Third, the Court of Appeals may consider whether the relief the District Court ordered — a reduction from a mandatory life sentence to time served, approximately eleven years — is consistent with a faithful application of the § 3553(a) factors in light of the offense of conviction.

Each of those questions falls within the discretion of the District Court in the first instance, subject to the deferential review of the Court of Appeals.

VI

The Government raised at argument a concern that the rule we adopt today will "super-charge" the use of § 3582(c)(1)(A) and produce a flood of motions raising repackaged § 2255 claims. Tr. of Oral Arg. 29. The concern is one we take seriously. We note three answers.

First, the demanding "extraordinary and compelling" threshold does its own work. Gonzalez v. Crosby, 545 U. S. 524, 535 (2005), made the same observation in the Rule 60(b) context: the "extraordinary circumstances" inquiry there "will rarely occur in the habeas context." The "extraordinary and compelling" threshold in § 3582(c)(1)(A)(i) is, if anything, more stringent.

Second, the empirical record post-First Step Act does not bear out the projection. The Sentencing Commission's most recent reports show grant rates in the single-digit percentages and a total annual grant universe under one-third of one percent of the federal prison population. Pet. Br. 33 & n. 3; NYCDL Br. 17–21. The First Circuit, which has applied a rule consistent with the one we adopt today since Trenkler, 47 F. 4th 42, has not seen the flood the Government projects. Pet. Reply 22 & n. 3.

Third, the structural protections AEDPA built into § 2255 — the one-year statute of limitations, the second-or-successive bar, the certificate-of-appealability requirement — remain in place where § 2255 is the operative vehicle. A defendant who could prevail under § 2255 but has been procedurally barred is not, for that reason alone, entitled to § 3582 relief; procedural default is not a reason within § 3582(c)(1)(A)(i)'s threshold. A defendant whose claim is barred is not freed from the bar by relabeling.

What the rule we adopt does is permit a district court, in a case meeting the high "extraordinary and compelling" threshold, to consider the full record before it — without an unwritten category-of-reasons exclusion the statute does not impose.

VII

The Court of Appeals correctly recognized that compassionate release is not a vehicle for the systematic relitigation of trial errors. But the rule it articulated to ensure that result reaches further than the text supports. Section 3582(c)(1)(A)(i) does not, on its terms, exclude reasons that could be alleged as grounds for vacatur under § 2255. The exclusion the Court of Appeals identified is not in the statute. It cannot be supplied by the general/specific canon, by the habeas-channeling line under Heck and Wilkinson, or by the substance-over-form rule the Court of Appeals adopted from its sister circuits. Reasons of any category may, where they satisfy the demanding threshold and where the requested relief does not necessarily imply the invalidity of the conviction, contribute to a finding of "extraordinary and compelling reasons" — subject in each instance to Commission policy statements, to the § 3553(a) factors, and to careful district-court discretion.

The judgment of the United States Court of Appeals for the Second Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.

It is so ordered.