## Facts

- Marcus DeAngelo Jones, a federal prisoner, was convicted in 2000 of two counts of being a 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 under § 922(a)(6).
- The Eighth Circuit affirmed his convictions and approximately 27-year sentence.
- Jones filed a timely motion under 28 U.S.C. § 2255; it resulted in vacatur of one concurrent § 922(g) conviction but no other relief.
- In 2019, the Supreme Court decided *Rehaif v. United States*, requiring the Government to prove, for a § 922(g) conviction, that the defendant knew both that he possessed a firearm and that he had the relevant prohibited status at the time.
- Relying on *Rehaif*, Jones sought to challenge his remaining § 922(g) conviction as legally invalid, but AEDPA limits second or successive § 2255 motions to narrow categories not covering intervening statutory interpretation.
- Jones filed a 28 U.S.C. § 2241 habeas petition in the district of confinement, invoking § 2255(e)’s saving clause on the theory that § 2255 was “inadequate or ineffective” to test his detention.
- The district court dismissed for lack of jurisdiction, and the Eighth Circuit affirmed; the Supreme Court granted certiorari.

## Issues

1. Whether § 2255(e)’s saving clause allows a federal prisoner to use § 2241 to raise an intervening statutory-interpretation claim when AEDPA bars a second or successive § 2255 motion asserting that claim.

## Decision

- The Supreme Court affirmed the Eighth Circuit.
- The Court held that § 2255(e) does not permit a prisoner to use § 2241 to bypass AEDPA’s restrictions on second or successive § 2255 motions based on an intervening change in statutory interpretation.
- The Court construed the saving clause to cover only limited situations where § 2255 is practically unavailable to test legality (e.g., unusual circumstances making relief in the sentencing court impossible or impracticable), not situations where § 2255 bars a particular claim.
- The Court rejected the argument that this reading violates the Suspension Clause, reasoning that claims of this type were not historically cognizable in habeas at common law.
- Dissents argued that the saving clause should permit review when intervening statutory interpretation indicates legal innocence and prior circuit law made the claim unavailable earlier.

## Legal Principles

- Section 2255 is the primary vehicle for federal prisoners’ collateral attacks; § 2241 is generally unavailable for such challenges absent the saving clause.
- The § 2255(e) saving clause concerns the adequacy of the remedial vehicle to test legality, not the availability of particular claims or favorable outcomes.
- AEDPA’s limits on successive § 2255 motions in § 2255(h) are part of the statutory scheme; inability to satisfy § 2255(h) does not make § 2255 “inadequate or ineffective” within § 2255(e).
- A federal prisoner may not use § 2241 as an end-run around § 2255(h) to litigate an intervening statutory-interpretation claim.

## Conclusion

The Court held that a federal prisoner who cannot meet AEDPA’s requirements for a second or successive § 2255 motion may not invoke § 2255(e)’s saving clause to pursue an intervening statutory-interpretation claim through a § 2241 habeas petition.


Jones v. Hendrix, 599 U.S. 465 (2023)