Camick v. United States, 687 F. App'x 719

In 2014 Leslie Lyle Camick was convicted of multiple offenses; the Tenth Circuit affirmed only his obstruction of justice conviction and reversed the rest, resulting in an amended judgment sentencing him to time served plus one year supervised release.
Camick filed a § 2241 habeas petition in the D. Kan. on Jan. 28, 2016, challenging the validity of his obstruction conviction under 18 U.S.C. § 1513(e).
The district court dismissed the § 2241 petition on June 7, 2016, concluding that a § 2255 motion, not § 2241, was the proper vehicle to challenge the conviction.
On appeal Camick raised claims including Brady violation, insufficient evidence, erroneous jury instructions, ineffective assistance of counsel, and actual innocence.
The central legal question was whether Camick could use § 2241 under the § 2255(e) savings clause to challenge the validity of his conviction rather than pursuing relief under § 2255.
The Tenth Circuit held that Camick failed to show § 2255 was inadequate or ineffective to test the legality of his detention, so the district court lacked jurisdiction to hear his § 2241 claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 2241 may be used to attack the validity of Camick's conviction	Camick argued § 2255 was inadequate/ineffective so the § 2255(e) savings clause permits a § 2241 challenge	Government argued § 2255 is the proper and adequate remedy; savings clause inapplicable	Held: § 2255(e) not satisfied; § 2241 unavailable to challenge conviction
Whether prior denial of a § 2255 motion makes § 2255 inadequate	Camick asserted prior § 2255 denial rendered § 2255 inadequate	Government: mere failure on § 2255 does not make it inadequate; Camick could have raised these claims in § 2255	Held: Failure to obtain relief under § 2255 does not render it inadequate or ineffective
Whether actual innocence invokes the savings clause	Camick argued actual innocence makes § 2255 inadequate	Government: actual innocence irrelevant to adequacy of § 2255 remedy	Held: Actual innocence is irrelevant to § 2255(e) adequacy test; claim was raised in § 2255 anyway
Whether procedural bars or prior rulings allow § 2241 review	Camick argued procedural obstacles justify § 2241	Government: procedural bars do not convert § 2255 into an inadequate remedy	Held: Procedural bar or prior denial does not permit bypassing § 2255 via § 2241

United States v. Camick, 796 F.3d 1206 (10th Cir. 2015) (prior appellate decision reversing most convictions)
Hale v. Fox, 829 F.3d 1162 (10th Cir. 2016) (discussing savings clause and limits on § 2241)
Prost v. Anderson, 636 F.3d 578 (10th Cir. 2011) (explaining § 2255(e) savings clause standard)
Abernathy v. Wandes, 713 F.3d 538 (10th Cir. 2013) (holding lack of § 2255(e) satisfaction deprives courts of jurisdiction to hear § 2241 claims)
Bradshaw v. Story, 86 F.3d 164 (10th Cir. 1996) (failure to obtain relief under § 2255 does not make the remedy inadequate)
Brady v. Maryland, 373 U.S. 83 (1963) (establishing prosecution's duty to disclose exculpatory evidence)