Cruz-Danzot v. United States of America, 4:17-cv-01393

Petitioner Miguel Angel Cruz-Danzot, federal inmate at USP-Canaan, filed a pro se § 2241 habeas petition challenging his guilty plea and sentence for conspiracy to possess with intent to distribute cocaine base (sentenced July 20, 2012 to 78 months).
He previously filed a direct appeal (dismissed as untimely) and a § 2255 motion in the sentencing court (dismissed as untimely on April 19, 2017) raising the same claims.
Cruz-Danzot argues his plea was involuntary/unknowing under post‑sentence Supreme Court decisions: Burrage, McFadden, and Rosemond.
He seeks to bring these challenges via § 2241 in the district where he is incarcerated rather than by a § 2255 motion in the sentencing court.
The district court screened the petition under Rule 4 of the Rules Governing Section 2254 Cases and considered whether the narrow Dorsainvil safety‑valve permits a § 2241 collateral attack on a federal sentence.
The court concluded § 2241 relief was unavailable here and dismissed the petition without prejudice, noting Cruz‑Danzot may seek authorization to file a successive § 2255 in the appropriate court of appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether petitioner may challenge the validity of his conviction/sentence via § 2241	Cruz‑Danzot: § 2241 is available because post‑conviction decisions (Burrage, Rosemond, McFadden) render his plea involuntary	Respondent: § 2255 is the proper vehicle; § 2241 is available only if § 2255 is inadequate or ineffective (Dorsainvil narrow exception)	Court: Denied — § 2241 not available; § 2255 is the exclusive remedy absent narrow Dorsainvil showing
Whether Burrage, Rosemond, McFadden create a retroactive basis to use § 2241	Petitioner: These cases undermine his conviction/sentence and thus justify § 2241 review	Respondent: Those decisions are not retroactive in collateral review or do not render conduct noncriminal	Court: Rejected — Burrage and Rosemond are not retroactive for collateral review; McFadden does not change substantive criminality applicable here
Whether petitioner showed inability to raise claims in § 2255 (Dorsainvil standard)	Petitioner: Had procedurally defaulted/time‑barred § 2255; seeks relief because of intervening Supreme Court rulings	Respondent: § 2255 was available; time bar or failure to prevail does not make it inadequate	Court: Rejected — petitioner did not meet the narrow Dorsainvil standard (no showing that conduct is no longer criminal or that he lacked prior opportunity)

Burrage v. United States, 134 S. Ct. 881 (2014) (but‑for causation required for death‑resulting drug enhancements)
Rosemond v. United States, 134 S. Ct. 1240 (2014) (accomplice liability requires advance knowledge of principal's conduct)
McFadden v. United States, 135 S. Ct. 2298 (2015) (knowledge element for controlled‑substance offenses)
In re Dorsainvil, 119 F.3d 245 (3d Cir. 1997) (§ 2241 available only where § 2255 is inadequate or ineffective; extremely narrow exception)
Cradle v. United States, 290 F.3d 536 (3d Cir. 2002) (inefficacy, not inability, determines § 2255 inadequacy; statute of limitations or denial of relief not enough)
Woodall v. Federal Bureau of Prisons, 432 F.3d 235 (3d Cir. 2005) (distinguishing challenges to conviction/sentence from challenges to execution of sentence under § 2241)