Drake v. Young, 5:19-cv-00524

Drake pleaded guilty (2008) to a crack-cocaine conspiracy, admitted career-offender status in his plea agreement, and received a 292-month sentence (later commuted to 188 months).
His plea agreement included an appellate/post-conviction waiver; Fourth Circuit dismissed most appellate claims and affirmed the judgment.
Drake filed a § 2255 motion (denied 2011) and multiple subsequent post‑conviction filings; later attempts were dismissed as successive or untimely.
While incarcerated at FCI Beckley, Drake filed a § 2241 petition (July 2019) asserting Due Process and Confrontation Clause violations for reliance on stipulated drug-quantity lab results and a Brady claim that a deputy lacked federal authority.
The court found Drake’s § 2241 petition attacks the validity of his conviction/sentence (not execution), and concluded he had not shown § 2255 to be inadequate or ineffective under the Fourth Circuit’s savings-clause framework.
Recommendation: dismiss the § 2241 petition and civil action for lack of jurisdiction because Drake cannot meet In re Jones/Wheeler savings-clause criteria.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 2241 is a proper vehicle because § 2255 is allegedly inadequate/ineffective	Drake contends his claims (Brady, Confrontation) and collateral consequences justify § 2241 review despite prior § 2255 filings	The government argues Drake attacks conviction/sentence, not execution; § 2255 is the proper remedy and the savings clause does not apply	Court: § 2255 is not inadequate or ineffective here; § 2241 jurisdiction not available → dismissal
Whether the court should reach the merits of Drake’s Brady and Confrontation claims	Drake asserts the government relied on lab quantity without chemist testimony and withheld evidence about the deputy’s status	Government says such merits claims should have been raised on direct appeal or by § 2255; procedural bars apply	Court: did not reach merits because jurisdictional/savings-clause criteria not met; claims dismissed for lack of jurisdiction

In re Jones, 226 F.3d 328 (4th Cir. 2000) (defines when § 2255 is "inadequate or ineffective" so a prisoner may proceed under § 2241)
United States v. Wheeler, 886 F.3d 415 (4th Cir. 2018) (extends savings-clause analysis to certain sentencing errors with retroactive substantive changes)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor must disclose materially exculpatory evidence)
Carafas v. LaVallee, 391 U.S. 234 (1968) (release from custody does not necessarily moot collateral-harms habeas claims)
Jones v. Cunningham, 371 U.S. 236 (1963) (parolee remains "in custody" for habeas jurisdiction)
Snyder v. Ridenour, 889 F.2d 1363 (4th Cir. 1989) (failure to file timely objections to a magistrate judge’s recommendation waives de novo review)
Thomas v. Arn, 474 U.S. 140 (1985) (procedural rules on objections to magistrate recommendations result in waiver if not followed)