Whether a sentencing error and resulting disparity can constitute an 'extraordinary and compelling reason' for a sentence reduction under 18 U.S.C. § 3582(c)(1)(A)

QUESTION PRESENTED In 2013, Rory Zirkelbach was sentenced to 235 months’ imprisonment as a career offender under U.S. Sentencing Guideline § 4B1.2 when he did not, in fact, qualify for that designation. In 2021, he moved for reduced sentence under the statute, 18 U.S.C. § 3582(c)(1)(A)@), arguing that the careeroffender sentencing error and resulting sentencing disparity was an “extraordinary and compelling” reason for a lesser sentence under the statute’s terms. The question presented is: Did the district court err when it imposed an extratextual limitation on its statutory authority to determine what amounts to an “extraordinary and compelling reason” for a sentence reduction by concluding that a sentencing error and disparity cannot be the basis for a motion under 18 U.S.C. § 3582(¢)(1)(A)? i