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Thursday, November 5, 2026 · Phoenix, AZ

Freed Under First Step Act, Tennessee Man Could Return to Prison After Supreme Court Ruling

A courtroom

WASHINGTON — Two years after his release, a Tennessee man who served 13 years for a nonviolent drug conviction could be sent back to prison because of a Supreme Court ruling, the Associated Press reported.

A federal judge freed Patrick Dewayne Smith, 47, in 2024 under rules adopted after the First Step Act, a criminal justice law passed during President Donald Trump’s first term. In May, the Supreme Court ruled that people sentenced under older, harsher laws cannot rely on the gap between their sentences and current penalties to seek compassionate 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. He now works two jobs and attends church with his family in rural Tennessee.

Smith is among about a dozen people nationwide who could be returned to prison because of the ruling, according to FAMM, a sentencing reform group. Without clemency from the White House, the group says, their second chances could disappear.

Thousands of people have been released since the law passed, but recent rulings have made it harder for others serving long sentences to argue for release.

Sources: Associated Press via KTAR News. Thee Arizona Times uses AI-assisted reporting reviewed against the sources listed.

Photo: Michael D Beckwith / CC0 via Wikimedia Commons.

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