Johnny Curtis Bedgood v. Warden, FCC Coleman Medium
859 F. App’x 471
| 11th Cir. | 2021Background
- Petitioner Johnny Bedgood, a federal prisoner proceeding pro se, filed a § 2241 habeas petition seeking vacatur of his conviction under 18 U.S.C. §§ 922(g), 924(e) based on the Supreme Court’s decision in United States v. Rehaif.
- The district court dismissed the § 2241 petition for lack of jurisdiction, concluding Bedgood failed to satisfy the § 2255(e) saving clause.
- Bedgood previously filed a § 2255 motion challenging the same conviction and sentence.
- Bedgood argued he could not have raised his Rehaif claim in his original § 2255 filing, so he sought to use § 2241 under the saving clause.
- The Eleventh Circuit reviewed de novo whether the saving clause permitted relief under § 2241 and whether the petition challenged execution of the sentence or the validity of conviction.
- The court affirmed dismissal, holding Bedgood’s Rehaif-based claim attacked the conviction (not execution), and § 2255 remained an adequate vehicle to test the claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bedgood may pursue a Rehaif claim via § 2241 under the § 2255(e) saving clause | Bedgood: Rehaif claim could not be brought in his § 2255 petition, so § 2255 was inadequate and § 2241 is available | District court/Government: Claim attacks conviction validity (not execution); § 2255 was an adequate remedy | Held: § 2255 adequate; saving clause not satisfied; § 2241 dismissed for lack of jurisdiction |
| Whether Rehaif supplies a new, retroactive rule permitting a successive § 2255 motion | Bedgood: Rehaif requires vacatur of § 922(g) convictions based on mens rea clarification | Court/Gov't: Rehaif is a clarification and Eleventh Circuit treats it as not announcing a retroactive new rule for successive § 2255 relief | Held: Even if Rehaif announced a new rule, it is not retroactively applicable for successive § 2255; claim remains cognizable under § 2255 and cannot be pursued via § 2241 |
Key Cases Cited
- United States v. Rehaif, 139 S. Ct. 2191 (2019) (Supreme Court clarified mens rea requirement for convictions under § 922(g))
- McCarthan v. Dir. of Goodwill Indus.-Suncoast, Inc., 851 F.3d 1076 (11th Cir. en banc 2017) (defines scope of § 2255(e) saving clause and when § 2241 is available)
- Amodeo v. FCC Coleman-Low Warden, 984 F.3d 992 (11th Cir. 2021) (explains meritless claims that attack legality remain cognizable under § 2255)
- In re Palacios, 931 F.3d 1314 (11th Cir. 2019) (held Rehaif did not announce a new retroactive rule for successive § 2255 relief)
- Antonelli v. Warden, U.S.P. Atlanta, 542 F.3d 1348 (11th Cir. 2008) (distinguishes collateral attacks on execution of sentence under § 2241 from challenges to conviction under § 2255)
- Sawyer v. Holder, 326 F.3d 1363 (11th Cir. 2003) (§ 2255 is primary vehicle for collateral attacks on conviction or sentence)
- Brown v. Warden, FCC Coleman-Low, 817 F.3d 1278 (11th Cir. 2016) (saving clause is a threshold jurisdictional issue)
- Al-Arian, 514 F.3d 1184 (11th Cir. 2008) (district court subject-matter jurisdiction reviewed de novo)