Two years after his release from prison, Patrick Dewayne Smith spends Sundays with his family in a modest brick church with a white steeple in rural Tennessee. He works two jobs. He goes to ball games to cheer for nieces and nephews he had never met. After serving 13 years for a nonviolent drug conviction, he is trying to rebuild his life.

Now Smith could be sent back to prison for the rest of it.

A federal judge released him in 2024 under rules adopted after Congress passed the First Step Act, a landmark criminal justice law during Donald Trump’s first term. But the Supreme Court ruled in May that people sentenced under older, harsher laws cannot rely on the disparity between their sentences and current penalties to seek early compassionate release.