What Is “Holloway” Relief, and Can It Shorten a Federal Sentence?

"Holloway" relief is a rare way to shorten a federal sentence. It works only if the prosecutor agrees to undo part of the case, usually by dismissing one or more counts, and the judge goes along with it. There are a lot of rumors about it in prison, so here is what it really is.

Update (October 2026): In 2018, the First Step Act ended "stacking" of § 924(c) gun sentences for new cases, but not for people already sentenced (Pub. L. 115-391, § 403). In May 2026, the Supreme Court held in Rutherford v. United States, No. 24-820, that this non-retroactive change cannot be an "extraordinary and compelling reason" for compassionate release (docket). That makes prosecutor-agreed relief like Holloway one of the few remaining paths for some stacked sentences.

The Holloway case

In 1995, Francois Holloway was convicted of three counts under 18 U.S.C. § 924(c), which punishes using or carrying a gun during a violent or drug crime. Those sentences were "stacked," meaning they ran one after another, for about 45 years. That was on top of 12.5 years for carjacking.

Years later, the U.S. Attorney for the Eastern District of New York, Loretta Lynch, agreed to dismiss two of the § 924(c) convictions. The judge then resentenced him to a total of 30 years, and Holloway went home.

You can read the opinion here: United States v. Holloway, 68 F. Supp. 3d 310 (E.D.N.Y. 2014).

Other courts that have done the same

A few other courts have let the government drop counts to allow a lower sentence:

• Southern District of New York: United States v. Washington, No. 11-cr-605 (RJS) (S.D.N.Y. July 31, 2014) (Sullivan, J.)
• Eastern District of Oklahoma: United States v. Rivera, No. 83-00096-01-CR (E.D. Okla. Sept. 15, 2015) (Seay, J.)
• Eastern District of Pennsylvania: United States v. Ezell, No. 02-815-01 (E.D. Pa. Aug. 18, 2015) (DuBois, J.); United States v. Trader, No. 04-680-06, 2015 WL 4941820 (E.D. Pa. Aug. 18, 2015) (DuBois, J.)

In every one of these cases, the government agreed to dismiss one or more counts, and the court allowed it.

Can Holloway relief help you?

Two things have to happen:

1. The prosecutor agrees to dismiss one or more counts.
2. The judge agrees to let them.

If the government refuses, or if you were convicted of only one count, Holloway relief is not available. Even when the facts are strong, this kind of relief is very rare. It can be worth asking, but go in with realistic expectations.

A request like this usually goes to the U.S. Attorney's Office in the district where you were sentenced. It helps to have the judgment (the court's final sentencing order), the docket number, and a record of your time in prison, such as program completions and work history, ready before anyone makes the ask.

Facing a federal sentence? Book a consultation to talk it through with Brandon Sample.