Mark Hill v. Bart Masters, 836 F.3d 591

Mark Hill was convicted in 2001 of conspiracy to distribute heroin and sentenced under the then-mandatory 2001 Sentencing Guidelines as a career offender based on two prior Maryland felonies, including second-degree assault, producing a 300-month sentence.
Hill pursued multiple postconviction challenges (§ 2255) and was barred from further successive § 2255 relief by statutory limits.
After Descamps (2013) and the Fourth Circuit’s Royal decision, Hill argued Maryland second-degree assault is not a "crime of violence," so his career-offender enhancement was misapplied.
Hill filed a § 2241 petition invoking the § 2255(e) savings clause to challenge his sentence enhancement; the district court dismissed it for failing to show "actual innocence."
The Sixth Circuit reversed, holding Hill may proceed under § 2241 because (1) he was sentenced under the mandatory Guidelines pre-Booker, (2) he is foreclosed from successive § 2255 relief, and (3) a retroactive change in statutory interpretation removed the predicate offense for his career-offender status.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hill can use § 2241 via the § 2255(e) savings clause to challenge a misapplied career-offender enhancement	Hill: Descamps and Royal announced a new statutory interpretation that retroactively shows his prior assault conviction is not a crime of violence, so § 2255 is inadequate and § 2241 is available	Gov: Savings clause should be limited; misapplied enhancement is not a "fundamental" defect unless the sentence exceeds the statutory maximum	Court: Allowed § 2241 relief in a narrow class of cases where (a) defendant was sentenced under mandatory pre-Booker Guidelines, (b) successive § 2255 is foreclosed, and (c) retroactive statutory interpretation removes the predicate offense for career-offender status
Whether a misapplied Guidelines enhancement that does not exceed the statutory maximum can be a "fundamental defect" for savings-clause purposes	Hill: Pre-Booker mandatory Guidelines had force of law; misclassification as career offender is a miscarriage of justice and denies eligibility for future reductions	Gov: Fundamental defects should be limited to errors like convictions for non-existent offenses or sentences above statutory maximums	Court: Misapplied career-offender enhancements under mandatory Guidelines can be sufficiently fundamental to permit relief under § 2241 in the narrow circumstances described

Descamps v. United States, 133 S. Ct. 2276 (2013) (clarified categorical approach and limited use of modified categorical approach for predicate-offense analysis)
United States v. Royal, 731 F.3d 333 (4th Cir. 2013) (applied Descamps to hold Maryland second-degree assault is not a violent felony)
Brown v. Caraway, 719 F.3d 583 (7th Cir. 2013) (permitted § 2241 challenge to misapplied career-offender enhancement for pre-Booker sentences)
Charles v. Chandler, 180 F.3d 753 (6th Cir. 1999) (discussed savings clause and limited circumstances where § 2255 is inadequate)
Peterman v. United States, 249 F.3d 458 (6th Cir. 2001) (narrow view of when savings clause applies; courts generally decline collateral review of sentences within statutory maximum)
Narvaez v. United States, 674 F.3d 621 (7th Cir. 2012) (recognized sentencing misclassification as miscarriage of justice warranting relief)
United States v. Surratt, 797 F.3d 240 (4th Cir. 2015) (panel denied § 2241 relief where sentence did not exceed statutory maximum; strong dissent argued broader availability of savings-clause relief)
Begay v. United States, 553 U.S. 137 (2008) (further developed the definition of predicate offenses for enhanced sentencing)
United States v. Booker, 543 U.S. 220 (2005) (rendered Guidelines advisory, distinguishing pre-Booker mandatory sentencing regime)