Whether non-retroactive changes in sentencing law can constitute extraordinary and compelling reasons for compassionate release under 18 U.S.C. § 3582(c)(1)(A)

QUESTION PRESENTED A court may grant compassionate release and reduce a sentence if, after evaluating the factors in 18 U.S.C. § 3553(a), it finds that extraordinary and compelling reasons so warrant. While rehabilitation alone cannot constitute a reason, nothing in the text of Section 3582 limits the factors a court may view as extraordinary and compelling. Can non-retroactive changes in sentencing law constitute extraordinary and compelling reasons as four circuits have held (the First, Second, Fourth, and Tenth), or are courts either prohibited or limited from considering such changes (the Third, Seventh, and Eighth circuits)? i