Jones v. Hendrix
599 U.S. 465
SCOTUS2023Background
- Marcus Jones was convicted in 2000 of two counts under 18 U.S.C. § 922(g)(1) (felon in possession) and one count under § 922(a)(6); the Eighth Circuit affirmed and Jones later obtained partial relief under an initial 28 U.S.C. § 2255 motion (one concurrent § 922(g) sentence vacated).
- In 2019 this Court decided Rehaif (defendant must know status that makes him ineligible under § 922(g)); that decision abrogated controlling Eighth Circuit precedent applied to Jones at trial and on direct appeal.
- Rehaif is a statutory (nonconstitutional) change in law that did not satisfy AEDPA’s § 2255(h) gates for second-or-successive motions (neither newly discovered evidence nor a new rule of constitutional law).
- Jones sought to invoke § 2255(e)’s “saving clause” to file a § 2241 habeas petition in the district of confinement (Eastern District of Arkansas) to press his Rehaif statutory claim; the district court and the Eighth Circuit dismissed for lack of jurisdiction.
- The Supreme Court granted certiorari and held that § 2255(e) does not permit a prisoner to use § 2241 via the saving clause to evade AEDPA’s second-or-successive restrictions for an intervening statutory interpretation like Rehaif.
Issues
| Issue | Plaintiff's Argument (Jones) | Defendant's Argument (United States) | Held |
|---|---|---|---|
| Whether § 2255(e)’s saving clause allows a § 2241 petition to assert a statutory claim barred as second or successive by AEDPA | The saving clause covers cases where § 2255 is “inadequate or ineffective” because a sentencing court (or circuit precedent) applied the wrong substantive law; thus § 2241 is available to raise Rehaif claims | The saving clause should be read against a habeas benchmark informed by state-prisoner habeas law; § 2255(h) does not render § 2255 inadequate for statutory claims simply because they are not listed | Held: No. The saving clause preserves § 2241 only for unusual practical obstacles or non-sentence detention challenges; it does not permit end‑runs around AEDPA’s § 2255(h) limits on second or successive motions. |
| Whether historical/Suspension Clause principles compel saving-clause access to collateral review for statutory-innocence claims | Denying a subsequent forum for a retroactive statutory-innocence ruling (like Rehaif) effectively condemns legally innocent prisoners; founding-era habeas and equitable traditions support habeas access | The Suspension Clause protects the writ as understood at founding, which did not permit relitigation of substantive statutory errors after final judgment; no constitutional command requires second-or-successive review for statutory errors | Held: Rejection. Historical practice and the Suspension Clause do not require Congress’s restrictions to be circumvented; Davis’s later innovation does not constitutionalize a right to successive collateral review. |
| Whether § 2255(h)’s text should be read to permit successive statutory claims because Congress did not explicitly bar them | Argues that the saving clause should preserve claims that were cognizable pre‑AEDPA and that omission of statutory claims from § 2255(h) reflects no clear congressional intent to foreclose them | Government contends § 2255(h) reasonably limits successive motions to the two listed categories and that there is no clear textual ambiguity requiring a saving-clause exception for statutory claims | Held: The Court applies a negative-inference reading: § 2255(h) enumerates the only gateways for successive motions; lack of inclusion of statutory claims means Congress did not authorize successive nonconstitutional statutory claims. |
| Whether the Government’s proposed benchmark (parity with state-prisoner habeas law) should control the saving-clause inquiry | Jones: not applicable; focus should be on adequacy of § 2255 as a remedy, not cross-reference to state habeas models | Government: § 2255(e) adequacy should be measured against the kinds of claims historically cognizable in federal habeas for state prisoners (thus limiting saving-clause openings) | Held: Rejected. No textual or historical basis to import a state-prisoner habeas benchmark into § 2255(e); AEDPA’s restrictions are best read as restrictions on § 2255, not expansions of § 2241. |
Key Cases Cited
- United States v. Hayman, 342 U.S. 205 (1952) (explains § 2255’s origin and purpose: to route federal prisoners’ collateral attacks to the sentencing court and to alleviate burdens on districts of confinement)
- Davis v. United States, 417 U.S. 333 (1974) (recognized that substantive statutory error could be cognizable in collateral attack under § 2255)
- Bailey v. United States, 516 U.S. 137 (1995) (example of an intervening statutory interpretation that produced collateral‑attack claims)
- Felker v. Turpin, 518 U.S. 651 (1996) (describes AEDPA’s changes as a modified res judicata rule and emphasizes congressional role in balancing finality and error correction)
- Boumediene v. Bush, 553 U.S. 723 (2008) (discusses relationship between statutory habeas mechanisms and constitutional habeas protections)
- Bousley v. United States, 523 U.S. 614 (1998) (statutory‑innocence claims can be indicative of miscarriage of justice and thus cognizable in collateral proceedings)
- Schriro v. Summerlin, 542 U.S. 348 (2004) (addresses retroactivity of new rules of criminal law)