Patrick Dewayne Smith faces return to prison after release in Washington
Patrick Dewayne Smith faces a return to federal prison after a ruling in Washington. A Supreme Court decision could undo his early release and send him back for life.
Smith served 13 years for a nonviolent drug conviction. A federal judge released him in 2024. He now lives in rural Tennessee and works two jobs.
The high court ruled in May on compassionate release rules. Inmates cannot cite changes in legal penalties to win early release.
“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.
The ruling could impact about a dozen people nationwide. The sentencing reform group FAMM reported the estimate. The group was formerly known as Families Against Mandatory Minimums.
“Having them reincarcerated is so unjust given that they have demonstrated their rehabilitation,” said Shanna Rifkin, general counsel for FAMM.
Congress passed the First Step Act during the first term of President Donald Trump. The law reduced some mandatory minimum terms for nonviolent drug crimes.
Trump said the law would give former inmates a second chance. His son-in-law, Jared Kushner, championed the measure. Kushner had a father who served time in federal prison.
A White House official said the administration is actively reviewing developments. The official spoke on condition of anonymity.
Supreme Court limits early releases
In 2023, the U.S. Sentencing Commission adopted new guidelines. Judges could consider legal changes for inmates jailed at least 10 years.
The Department of Justice opposed those rules. The department argued the commission exceeded what the statute allowed.
The Supreme Court agreed in a 6-3 decision in May. Decades-old sentencing disparities are not extraordinary reasons for release, the court found.
“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,” Justice Amy Coney Barrett wrote for the majority.
The ruling narrowed release options, said New York University law professor Daniel Harawa. He said he worries about federal criminal justice reform.
Smith grew up in northern Alabama and became addicted to drugs as a teenager. Lawyers detailed his background in court documents.
He was arrested at 17 for selling crack cocaine to an informant. Two marijuana convictions followed. He served about three years in prison.
Smith worked construction and janitorial jobs. In 2010, he joined a drug ring on the Tennessee-Alabama line, prosecutors said.
The U.S. Drug Enforcement Administration recorded him on phone calls. Smith rejected a plea deal of 12 to 14 years. He was convicted of drug conspiracy and money laundering.
The prior convictions triggered a mandatory life sentence. The judge questioned the harsh punishment, but federal law bound her.
“What kept me sane was that faith, that belief in God,” Smith said.
His mother died during his first year in prison. He could not afford the $1,000 travel cost for her funeral.
Smith won release in 2024. He moved in with his sister and her daughter in Alabama.
Prosecutors filed court documents last month to challenge his release. They cited the recent high court ruling in Washington.
Current laws require a 25-year mandatory minimum sentence, prosecutors argued. They called his early release difficult to justify.
A Justice Department official said his release is no longer valid. The department cannot accept a sentence below legal mandates, the official said.
The effort upsets his father, James Smith, an elder at Willow Grove Missionary Baptist Church. He said taking his son back for life on a nonviolent case does not sit well.
Compassionate release allows federal judges to reduce prison terms for extraordinary and compelling reasons. Presidential clemency grants can reduce sentences or forgive federal convictions entirely.
Smith now attends a small church in Tennessee. He spends weekends with family. He hopes to stay free.
