Chadrick Fulks v. T. Watson, 4 F.4th 586

Chadrick Fulks was convicted in 2004 of federal carjacking, kidnapping, and murder and received two death sentences; defense presented IQ scores (about 75–79) and mitigation but did not argue Atkins intellectual disability at trial.
Fulks filed a §2255 motion in 2008 raising multiple claims (ineffective assistance, etc.) but did not assert Atkins or ineffective assistance for failing to raise it; §2255 relief was denied and appeals were unsuccessful.
In 2015 Fulks filed a pro se §2241 habeas petition (later amended) asserting for the first time that, under updated clinical manuals (AAIDD–2012 and DSM‑5) and later Supreme Court decisions, he is intellectually disabled and ineligible for the death penalty; a 2018 neuropsychological evaluation supported that diagnosis.
The district court dismissed the §2241 petition, concluding Fulks failed to show §2255 was "inadequate or ineffective" under the savings clause and thus could not use §2241 to raise Atkins.
The Seventh Circuit affirmed, relying on its savings‑clause jurisprudence (including Bourgeois and Purkey) and reasoning that updated legal or diagnostic standards do not, by themselves, create the structural defect in §2255 required to access §2241.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Fulks may invoke §2255(e) savings clause to bring an Atkins claim in §2241 based on post‑2008 legal and diagnostic changes	Fulks: AAIDD‑2012/DSM‑5 and later Supreme Court decisions made an Atkins claim unavailable earlier, so §2255 was inadequate	Gov: §2255 was not inadequate; Fulks had an opportunity in 2008 to raise Atkins and mere likelihood of failure is not adequacy failure	Savings clause not satisfied; §2241 unavailable; claim dismissed and affirmed
Whether Madison v. Alabama supplies an independent functional‑equivalence ground permitting §2241 relief	Fulks: Madison permits functional‑equivalence challenges (like Atkins) and thus provides a new ground unavailable in 2008	Gov: Madison addresses competency to be executed (Ford/Panetti line), not a new Atkins rule; it does not render §2255 inadequate	Madison does not change result; claim is effectively Atkins and could have been raised earlier; no §2241 relief

Atkins v. Virginia, 536 U.S. 304 (established Eighth Amendment bar on executing intellectually disabled persons)
Hall v. Florida, 572 U.S. 701 (rejected rigid IQ cutoff; courts must heed medical diagnostic frameworks)
Moore v. Texas, 137 S. Ct. 1039 (2017) (Moore I) (reiterated requirement to follow medical community standards)
Moore v. Texas, 139 S. Ct. 666 (2019) (Moore II) (reinforced errors by state court in applying Atkins)
Madison v. Alabama, 139 S. Ct. 718 (2019) (addressed competency to be executed under Ford/Panetti line)
Bourgeois v. Watson, 977 F.3d 620 (7th Cir. 2020) (rejected use of savings clause to raise new Atkins claim after §2255)
Purkey v. United States, 964 F.3d 603 (7th Cir. 2020) (explained narrow scope of §2255 savings clause)
Webster v. Daniels, 784 F.3d 1123 (7th Cir. 2015) (en banc) (explained savings clause requires a structural inadequacy of §2255)
In re Davenport, 147 F.3d 605 (7th Cir. 1998) (one recognized instance where §2255 was inadequate)