CHI v. TRATE, 1:20-cv-00049

Petitioner Anson Chi, a federal inmate at FCI McKean, filed a habeas petition under 28 U.S.C. §2241 (received Mar. 3, 2020; amended Apr. 29, 2020). Respondent is the Warden of FCI‑McKean.
Chi previously filed a §2255 motion in the U.S. District Court for the Eastern District of Texas challenging his conviction; that §2255 motion was denied.
Magistrate Judge Richard A. Lanzillo issued a Report & Recommendation (R&R) on July 20, 2022, concluding the §2241 petition must be dismissed for lack of jurisdiction because it attacks the validity of the conviction rather than the execution of the sentence.
The magistrate applied the Third Circuit’s rule that §2241 is only available to challenge a conviction when §2255 is “ineffective or inadequate” (In re Dorsainvil and Bruce v. Warden Lewisburg USP frameworks) and found Chi failed to show §2255 was inadequate.
Chi objected to the R&R, claiming the magistrate misstated his claims, alleging a conspiracy to deny relief, and disputing the magistrate’s decision to stay proceedings pending the sentencing court’s ruling on his §2255 motion.
The district court (Judge Susan Paradise Baxter) conducted de novo review, adopted the R&R, dismissed the §2241 petition for lack of jurisdiction, and closed the case. The Warden was substituted as the respondent per Rule 25(d).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court has jurisdiction to hear Chi’s §2241 petition	Chi contends his §2241 claims are properly before the court and repeat or supplement prior §2255 arguments	Respondent argues Chi attacks the validity of his conviction, not the sentence’s execution, so §2241 is improper jurisdictionally	Court held there is no jurisdiction under §2241 because the petition attacks conviction validity and not sentence execution
Whether §2255 is an inadequate or ineffective remedy such that §2241 is permitted (Dorsainvil exception)	Chi argues circumstances (including procedural delay and prior adverse §2255 outcome) render §2255 inadequate	Respondent argues Chi has not shown §2255 to be inadequate per controlling Third Circuit precedent	Court held Chi did not meet the Dorsainvil/Bruce standard; §2255 remains the proper vehicle, so §2241 relief is unavailable
Whether the magistrate erred by staying proceedings or by allegedly distorting Chi’s claims	Chi argues the stay/computation delayed relief and that the R&R mischaracterized his claims; alleges a conspiracy	Respondent defends the magistrate’s handling and notes proper referral and procedures were followed	Court found Chi’s objections meritless, affirmed the magistrate’s procedures and conclusions, and adopted the R&R

In re Dorsainvil, 119 F.3d 245 (3d Cir. 1997) (establishes when §2255 is "inadequate or ineffective" to permit §2241 review of a conviction)
Bruce v. Warden Lewisburg USP, 868 F.3d 170 (3d Cir. 2017) (applies and clarifies the Dorsainvil standard for §2241 jurisdiction)