Timothy L. Richards v. United States

Enacted in the Sentencing Reform Act of 1984, 18 U.S.C. § 3582(a) declares that “imprisonment is not an appropriate means of promoting correction and rehabilitation.” In Tapia v. United States, this Court held that “the Sentencing Reform Act precludes federal courts from imposing or lengthening a prison term in order to promote a criminal defendant’s rehabilitation.” 564 U.S. 319, 321 (2011). The Courts of Appeals are split 5 to 7 over how to apply that rule. See United States v. Schonewolf, 905 F.3d 683, 691 (3d Cir. 2018) (cataloguing the split as of 2018). Today the Sixth, Ninth, Tenth, Eleventh, and D.C. Circuits understand Tapia and § 3582(a) to prohibit any reliance on rehabilitation when imposing a prison sentence. Meanwhile the First, Second, Third, Fourth, Fifth, Seventh, and Eighth Circuits take the “intermediate position,” Esteras v. United States, 606 U.S. 185, 190 n.1 (2025), that Tapia and § 3582(a) forbid only prison sentences based primarily on rehabilitation. The question presented is whether any reliance on rehabilitation when imposing a prison term violates 18 U.S.C. § 3582(a).