Derrick Taylor v. Angela Owens, 990 F.3d 493

Derrick Taylor robbed a bank at gunpoint, led police on a high-speed chase, killed one driver, shot another, and abducted a woman and child; he was convicted under statutes including 18 U.S.C. § 2113(e).
Taylor previously filed a § 2255 motion in 2005 (challenging sentencing procedures post-Booker); the district court denied it as time‑barred and this court denied a COA.
In 2018 Taylor filed a § 2241 habeas application claiming actual innocence because the government never proved intent to kill while avoiding arrest. He relied on United States v. Parks and Elonis v. United States.
The district court denied the § 2241 petition on the merits and dismissed with prejudice. Taylor appealed.
The Sixth Circuit held that 28 U.S.C. § 2255(e) is a jurisdictional bar to entertaining a § 2241 petition when § 2255 relief was available and not shown to be inadequate or ineffective.
The court ruled Taylor failed to satisfy the saving clause (he could not rely on Parks or Elonis to show § 2255 was inadequate), vacated the merits decision, and remanded with instructions to dismiss for lack of subject‑matter jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 28 U.S.C. § 2255(e) is a jurisdictional bar to § 2241 habeas jurisdiction	§ 2255(e) does not deprive district courts of jurisdiction over § 2241 petitions	§ 2255(e) plainly tells courts not to entertain certain § 2241 petitions and thus limits subject‑matter jurisdiction	§ 2255(e) is jurisdictional; district courts lack jurisdiction when § 2255 relief was available and not shown inadequate
Whether Taylor met the saving clause (§ 2255 inadequate/ineffective) by relying on Parks and Elonis	Parks and Elonis changed the law to require proof of intent to kill, showing actual innocence and inadequacy of § 2255	Parks is a Sixth Circuit decision (not Supreme Court) and Elonis interprets a different statute, so neither satisfies the saving clause	Taylor failed to meet the saving‑clause burden; he did not identify a post‑§2255 Supreme Court decision that reinterpreted the statute of conviction
Proper remedy for the district court’s adjudication of the § 2241 petition	District court could adjudicate merits	District court lacked jurisdiction and therefore should have dismissed (not decide merits)	Vacated the district court’s merits decision and remanded with instructions to dismiss for lack of subject‑matter jurisdiction

Felker v. Turpin, 518 U.S. 651 (AEDPA provisions can limit courts’ power to entertain habeas petitions)
Ex parte Yerger, 75 U.S. (8 Wall.) 85 (historical discussion of Court’s power to entertain habeas)
Henderson ex rel. Henderson v. Shinseki, 562 U.S. 428 (clear‑statement rule for jurisdictional statutes)
Boumediene v. Bush, 553 U.S. 723 (habeas jurisdiction principles)
Kontrick v. Ryan, 540 U.S. 443 (distinguishing jurisdictional rules from claim‑processing rules)
Wright v. Spaulding, 939 F.3d 695 (describing § 2255 as primary means to challenge convictions)
Hueso v. Barnhart, 948 F.3d 324 (explaining saving‑clause framework)
United States v. Parks, 583 F.3d 923 (6th Cir. decision Taylor relied on)
Elonis v. United States, 135 S. Ct. 2001 (Supreme Court decision interpreting a different criminal statute)
United States v. Poindexter, 44 F.3d 406 (affirming Taylor’s convictions without requiring intent to kill)
Williams v. Warden, Fed. Bureau of Prisons, 713 F.3d 1332 (11th Cir. treating § 2255(e) as a jurisdictional bar)
United States v. Wheeler, 886 F.3d 415 (4th Cir. same conclusion on § 2255(e) jurisdictional effect)