## Facts

- Markus DeAngelo Jones was convicted in federal court of two counts of felon-in-possession of a firearm under 18 U.S.C. § 922(g)(1) and one count of making false statements to acquire a firearm.
- The Eighth Circuit affirmed on direct appeal.
- Jones sought collateral relief under 28 U.S.C. § 2255; one concurrent § 922(g) sentence was vacated, but one § 922(g) conviction remained.
- After the Supreme Court decided Rehaif v. United States, holding that a § 922(g) conviction requires proof the defendant knew of the status that barred firearm possession, Jones argued he was legally innocent under the new statutory interpretation.
- Unable to satisfy the limits on second or successive § 2255 motions in § 2255(h), Jones filed a 28 U.S.C. § 2241 habeas petition in the district of confinement invoking § 2255(e)’s saving clause.
- The district court dismissed for lack of jurisdiction, and the Eighth Circuit affirmed.

## Issues

1. Whether § 2255(e)’s saving clause permits a federal prisoner to use § 2241 to assert an intervening change in statutory interpretation when AEDPA bars a second or successive § 2255 motion under § 2255(h).
2. Whether denying a § 2241 forum for such a claim violates the Suspension Clause.

## Decision

- The Supreme Court affirmed the Eighth Circuit.
- Section 2255(e) does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to bypass AEDPA’s restrictions on second or successive § 2255 motions by filing a § 2241 petition.
- The saving clause applies to unusual circumstances where § 2255 is unavailable in a practical or jurisdictional sense, not when § 2255 relief is foreclosed by § 2255(h).
- This reading does not violate the Suspension Clause because the asserted statutory-interpretation innocence claim is outside the historical scope of habeas at the Founding.

## Legal Principles

- Section 2255 is the ordinary postconviction vehicle for federal prisoners to collaterally attack convictions and sentences in the sentencing court, generally displacing § 2241 petitions in the district of confinement.
- The § 2255(e) saving clause is an exception aimed at situations where the § 2255 process cannot be used to test legality (e.g., practical or jurisdictional unavailability), not a means to avoid limits Congress placed on successive collateral review.
- AEDPA’s § 2255(h) authorizes second or successive § 2255 motions only for newly discovered evidence or new rules of constitutional law made retroactive; intervening statutory interpretations are not included.
- Using § 2241 to raise barred statutory-interpretation claims would defeat § 2255(h)’s specific limits and Congress’s finality-focused design.
- The Suspension Clause is not violated by restricting § 2241 in this setting where the claimed basis for relief is not within the historical core of habeas.

## Conclusion

The Court held that § 2255(e)’s saving clause does not permit a federal prisoner to file a § 2241 petition based on a later statutory-interpretation decision when the claim would be a second or successive collateral attack barred by § 2255(h), and that this limitation is consistent with the Suspension Clause.


Jones v. Hendrix, 143 S. Ct. 1857 (2023)