Craig v. United States, 20-1318

Cornelius Kenyatta Craig filed a habeas petition under 28 U.S.C. § 2241 challenging the validity of his sentence.
The district court dismissed the § 2241 petition, ruling Craig’s sole remedy was a § 2255 motion to vacate.
On appeal Craig argued (1) cause and prejudice/miscarriage of justice to overcome procedural default, (2) equitable tolling of the limitations period, and (3) that a § 2255 motion would be inadequate or ineffective.
The district court’s dismissal rested only on lack of statutory jurisdiction: § 2241 is available to challenge a sentence only when § 2255 is inadequate or ineffective.
The court found Craig could have raised his claim in an initial § 2255 motion and thus § 2255 was not inadequate or ineffective; the Tenth Circuit affirmed.
The court granted in forma pauperis status, denied leave to amend the opening brief, and declined to await Edwards v. Vannoy because jurisdictional defect made the anticipated decision immaterial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural default	Craig: showed cause & prejudice / miscarriage of justice to excuse default	District: did not base dismissal on procedural default	Not dispositive — district didn’t rely on this, so it didn’t help Craig
Timeliness	Craig: limitations period was equitably tolled	District: dismissal did not rest on timeliness; § 2241 has no limitations period	Not dispositive — irrelevant to district court’s jurisdictional ruling
Statutory jurisdiction (adequacy of § 2255)	Craig: § 2255 would be inadequate or ineffective, so § 2241 is proper	District: Craig could have raised the claim in an initial § 2255 motion, so § 2255 is adequate	Held: § 2255 was not inadequate or ineffective; § 2241 petition dismissed for lack of statutory jurisdiction; affirmed

United States v. Cook, 997 F.2d 1312 (10th Cir. 1993) (procedural-default principles for § 2255 motions)
Prost v. Anderson, 636 F.3d 578 (10th Cir. 2011) (§ 2241 may be used only when § 2255 is inadequate or ineffective; adequacy requires inability to raise claim in an initial § 2255)
Edwards v. Vannoy, 140 S. Ct. 2737 (2020) (Supreme Court decision noted but not outcome-determinative here)