Patrick Dewayne Smith faces life sentence return following Washington ruling
Alabama resident Patrick Dewayne Smith faces possible reincarceration after a Supreme Court ruling narrowed compassionate release standards.
Patrick Dewayne Smith faces a potential return to prison after a Washington high court ruling. The federal decision threatens to erase his release two years into rebuilding his life. He was freed in 2024 under rules tied to the First Step Act.
The Supreme Court ruled 6-3 in May on compassionate release terms. Decades-old sentencing disparities are no longer considered extraordinary reasons for early release, the court found. About a dozen individuals nationwide face possible reincarceration, according to reform group FAMM.
“Every time I get a call, I’m hoping it’s some good news. Or, you know, at least not no bad news,” Smith said.
Smith served 13 years on nonviolent drug and money laundering convictions. He now lives in Alabama and works two jobs. The 47-year-old also attends a rural church across the border in Tennessee.
Federal officials challenged his freedom last month in court documents. Prosecutors argued he remains subject to a mandatory 25-year term under current laws. They called the earlier decision to free him difficult to justify.
“Having them reincarcerated is so unjust given that they have demonstrated their rehabilitation,” said Shanna Rifkin, general counsel for FAMM.
Without presidential clemency, those releases could be reversed, FAMM said. A Washington official stated the administration is reviewing developments. That official spoke on condition of anonymity because they lacked authorization to speak publicly.
The dispute centers on changes by the U.S. Sentencing Commission in 2023. Those provisions let judges weigh statutory updates for prisoners serving long terms. The Department of Justice opposed the guidelines.
Justice Amy Coney Barrett wrote the majority opinion for the high court.
“It is hard to see how Congress’s deliberate decision not to extend newly reduced penalties to those already sentenced could be a convincing reason that ‘warrant(s)’ a reduction,” Barrett wrote.
Smith had been arrested at age 17 for selling crack cocaine. Later marijuana convictions followed in northern Alabama, according to court filings. In 2010, the U.S. Drug Enforcement Administration recorded him on phone calls.
Smith rejected a plea deal that offered 12 to 14 years. His conviction in the 20-person case brought a mandatory life term. His father, James Smith, criticized the push to return him to prison.
“When you got rapists and murderers and you get this guy on a nonviolent case and you want him for life, it doesn’t sit well with me,” the elder Smith said.
Compassionate release allows federal judges to reduce prison terms for extraordinary and compelling reasons. The First Step Act permitted defendants to file these requests directly to courts. Decisions depend on statutory limits set by federal lawmakers.
Smith spent his first year in prison mourning his mother. Now back home, he waits on federal motions that could reverse his freedom.


