*Kenneth Wyatt II I. What is “Extraordinary and Compelling”? For almost five decades, people incarcerated in federal prisons have faced barriers to early release from their sentences.[1] However, in 2018, Congress passed the First Step Act (FSA). The FSA, among other things, amended the U.S. Code’s compassionate release statute,[2] granting courts the ability to actContinue reading ““Extraordinary and Compelling”: The Circuit Split Barrier to Compassionate Release Motions”