Jones v. Hendrix, 599 U.S. 465

Background

Marcus Jones was convicted in 2000 of felon-in-possession under 18 U.S.C. §922(g)(1); the Eighth Circuit affirmed and he was sentenced to 327 months.
Jones obtained partial relief via a timely §2255 motion (one concurrent §922(g) sentence vacated) but remained convicted on a separate §922(g) count.
In Rehaif (2019), the Supreme Court held that knowledge of prohibited status is an element of §922(g), overruling prior Eighth Circuit precedent applied to Jones.
AEDPA (§2255(h)) bars most second or successive §2255 motions unless they rely on newly discovered evidence or a new rule of constitutional law, so Jones could not bring a new §2255 motion based on Rehaif.
Jones filed a §2241 habeas in the district of confinement invoking §2255(e)’s "saving clause" (that §2241 is available when the §2255 remedy is "inadequate or ineffective"); the district court and Eighth Circuit dismissed for lack of jurisdiction.
The Supreme Court held that §2255(e)’s saving clause does not permit bypassing AEDPA’s second-or-successive limits by using §2241 to raise intervening statutory-interpretation claims; therefore Jones’ §2241 petition was not available.

Issues

Issue	Jones' Argument	Government's Argument	Held
Whether §2255(e)’s saving clause allows a federal prisoner to use §2241 to raise a statutory claim that AEDPA bars as a second or successive §2255 motion	Saving clause preserves habeas where §2255 is "inadequate or ineffective" to test detention; AEDPA’s limits render §2255 inadequate for statutory claims like Rehaif	The saving clause does not override §2255(h); AEDPA’s successive‑petition limits control and §2241 cannot be used to circumvent them	No — the saving clause does not authorize using §2241 to evade AEDPA’s §2255(h) limits
Whether a sentencing‑court or circuit error in applying substantive law makes §2255 itself "inadequate or ineffective"	If the §2255 forum applies incorrect law, the remedy is inadequate; petitioner lacks any meaningful forum for the claim	The saving clause concerns the remedial vehicle’s adequacy, not judicial error; precedent binding at the time does not make the remedy inadequate	No — judicial error or unfavorable circuit precedent does not convert §2255 into an inadequate vehicle for §2241 relief
Whether denying §2241 relief here violates constitutional protections (Suspension Clause, Due Process, Eighth Amendment, separation of powers)	Denial forecloses relief for possibly legally innocent prisoners and may violate habeas/Suspension Clause and other constitutional norms	Historical practice and precedents do not support extending the writ to relitigate substantive statutory errors after final judgment; Suspension Clause does not constitutionalize post‑Davis collateral review	No — the Court rejects constitutional arguments and finds historical practice does not require extending habeas to cover such successive statutory claims

Key Cases Cited

Rehaif v. United States, 588 U.S. _ (2019) (held defendant must know prohibited status to be guilty under §922(g))
United States v. Hayman, 342 U.S. 205 (1952) (explains §2255’s creation and the saving clause’s purpose)
Davis v. United States, 417 U.S. 333 (1974) (recognized substantive statutory error as cognizable in collateral attack under §2255)
Bailey v. United States, 516 U.S. 137 (1995) (example of a circuit‑splitting statutory narrowing that produced collateral claims)
Ex parte Watkins, 3 Pet. 193 (1830) (early limit on habeas relitigating convictions; treated as background on historical scope)
Felker v. Turpin, 518 U.S. 651 (1996) (describes AEDPA’s finality focus and limits on successive collateral attacks)
McCleskey v. Zant, 499 U.S. 467 (1991) (discusses miscarriage‑of‑justice doctrine in successive collateral contexts)
In re Dorsainvil, 119 F.3d 245 (3d Cir. 1997) (Circuit precedent applying the saving clause to allow §2241 for certain statutory claims)
Triestman v. United States, 124 F.3d 361 (2d Cir. 1997) (similar Circuit‑level saving‑clause approach)
In re Davenport, 147 F.3d 605 (7th Cir. 1998) (similar Circuit precedent invoking the saving clause)