## Facts

- Hayman was convicted in federal court and sentenced to 20 years’ imprisonment for forging government checks and related offenses.
- After enactment of 28 U.S.C. § 2255, Hayman moved in the sentencing court to vacate his sentence and obtain a new trial.
- He alleged ineffective assistance of counsel based on an undisclosed conflict: his attorney allegedly represented both Hayman and Juanita Jackson, a principal witness against him and a defendant in a related case, without Hayman’s knowledge or consent.
- The district court concluded the allegations warranted a hearing but held a three-day evidentiary proceeding without notice to Hayman and without ordering his presence.
- Based on that ex parte proceeding, the district court found the dual representation occurred with Hayman’s knowledge and consent and denied relief.
- The court of appeals held the § 2255 procedure, as applied, was inadequate and ineffective (and alternatively unconstitutional insofar as it limited habeas corpus) and ruled for Hayman.
- The Supreme Court granted review.

## Issues

1. Whether a sentencing court may decide disputed material facts under § 2255—especially facts about the prisoner’s own knowledge and consent—without notice to the prisoner and without producing the prisoner for a hearing.
2. Whether § 2255 is an inadequate or ineffective substitute for habeas corpus, or unconstitutional, when applied to bar habeas relief after such a proceeding.
3. Whether the sentencing court has authority to order a prisoner produced from another district for a § 2255 hearing.

## Decision

- The Supreme Court reversed and remanded.
- The district court erred by resolving controverted factual issues relating to Hayman’s own knowledge and consent without notice to him and without his presence.
- The Court construed § 2255 as a procedural substitute for habeas corpus that preserves prisoners’ substantive collateral-attack rights.
- The sentencing court has authority under § 2255 to order the prisoner produced from another district when necessary to resolve substantial factual disputes.
- Because the error could be cured by a proper hearing with Hayman present, the Court did not reach the broader constitutional questions.

## Legal Principles

- Section 2255 channels federal prisoners’ collateral attacks to the sentencing court to address practical problems of habeas administration, not to reduce the scope of collateral review.
- A § 2255 remedy is “adequate and effective” when it provides a meaningful opportunity to test the legality of detention; if it is inadequate or ineffective, habeas corpus remains available.
- When a § 2255 motion presents substantial, controverted factual issues involving events in which the prisoner participated or facts within the prisoner’s own knowledge, the sentencing court should require the prisoner’s production for a hearing, with notice.
- The sentencing court’s power to order the prisoner produced is auxiliary to the jurisdiction granted by § 2255 and is not negated by the prisoner’s confinement in another district.

## Conclusion

The Court held that § 2255 is designed to provide the same substantive collateral-review protections as habeas corpus in a more convenient forum, and that it was improperly applied when the sentencing court resolved disputed material facts about the prisoner’s knowledge and consent through an ex parte proceeding; the case was remanded for a hearing with the prisoner present.


United States v. Hayman, 342 U.S. 205 (1952)