## Facts

- Charles Edward Sanders, a federal prisoner, was convicted of bank robbery under 18 U.S.C. § 2113(a) after waiving indictment and pleading guilty without counsel.
- Sanders filed a first motion under 28 U.S.C. § 2255 alleging an invalid charging instrument, denial of counsel, and coercion to plead guilty; it stated conclusions without supporting facts.
- The district court denied the first motion without an evidentiary hearing, finding the record conclusively showed no entitlement to relief.
- About eight months later, Sanders filed a second § 2255 motion alleging he was mentally incompetent at plea and sentencing due to narcotics administered while jailed; the motion alleged specific supporting facts.
- The district court denied the second motion without a hearing, reasoning the incompetency claim should have been raised in the first motion.
- The Ninth Circuit affirmed the denial, and the Supreme Court granted review.

## Issues

1. When may a federal court give controlling weight to the denial of a prior § 2255 motion and refuse to consider a later motion?
2. Whether a district court may deny, without an evidentiary hearing, a § 2255 motion alleging fact-specific mental incompetence at plea and sentencing when the claim was not raised in the first motion.

## Decision

- The Supreme Court reversed and remanded.
- A prior denial controls a later § 2255 motion only if: (1) the same ground was previously decided against the prisoner, (2) the earlier decision was on the merits, and (3) the ends of justice would not be served by reconsideration.
- If the prior motion was not decided on the merits or the later motion raises a different ground, the court may avoid the merits only upon a properly raised claim of abuse of the remedy, which must be pleaded by the government.
- Sanders’s second motion asserted a different ground supported by alleged facts outside the original record, and the first motion had not been adjudicated on the merits; the district court therefore should have held a hearing.
- On remand, a hearing was required, but the district court retained discretion regarding the scope of the hearing and whether Sanders needed to be produced to testify.

## Legal Principles

- Denial of a prior § 2255 motion bars a later motion only when the later motion repeats the same ground, the prior denial was on the merits, and reconsideration would not serve the ends of justice.
- A dismissal because a motion is conclusory, without resolving factual disputes, is not an adjudication on the merits for preclusion of a later, fact-supported claim.
- When a later § 2255 motion presents a different ground or the earlier denial was not on the merits, dismissal is permitted only if the government pleads and proves abuse of the § 2255 remedy.
- Section 2255 requires a hearing unless the motion and the case files and records conclusively show the prisoner is not entitled to relief; allegations of facts outside the record that would warrant relief if true ordinarily require an evidentiary hearing.

## Conclusion

The Court required federal courts to evaluate successive § 2255 motions under a limited preclusion rule tied to “same ground,” “on the merits,” and “ends of justice,” and held that a distinct, fact-supported incompetency claim based on matters outside the record could not be rejected without a hearing absent a government-pleaded showing of abuse of the remedy.


Sanders v. United States, 373 U.S. 1 (1963)