Patterson v. United States, 3:15-cv-00098

Patterson pleaded guilty in 2007 to being an armed career criminal under 18 U.S.C. §§ 922(g)(1) and 924(e) and was sentenced to 180 months’ imprisonment.
The indictment listed four prior convictions (firearm possession and three state drug delivery convictions from 1986–1994) used to enhance under the ACCA.
Patterson unsuccessfully appealed his sentence to the Third Circuit in 2008 and later filed a § 2255 motion in 2009, which he amended and the district court denied in 2010. He did not previously challenge whether his prior drug convictions qualified as ACCA predicates.
After Johnson v. United States (2015) invalidated the ACCA residual clause—and Welch (2016) made Johnson retroactive—Patterson filed a pro se § 2241 petition arguing his ACCA enhancement is invalid under Johnson.
The government moved to dismiss for lack of jurisdiction, arguing § 2241 is not the correct vehicle for a sentencing challenge that should proceed under § 2255. The district court agreed and concluded it lacked jurisdiction to grant § 2241 relief.
In the interest of justice, the district court transferred the matter to the Third Circuit under 28 U.S.C. § 1631 for treatment as a motion for authorization to file a successive § 2255 motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Patterson may challenge his ACCA enhancement via § 2241 after Johnson/Welch	Johnson invalidates the ACCA residual clause; Patterson’s sentence is therefore unlawful and should be vacated; § 2241 is an available habeas vehicle	Patterson’s claim attacks his sentence and must be brought under § 2255; § 2241 is unavailable unless § 2255 is inadequate or ineffective	§ 2241 is unavailable; court lacks jurisdiction to decide the claim and transfers the filing to the Third Circuit for authorization to file a successive § 2255 motion

Johnson v. United States, 135 S. Ct. 2551 (2015) (invalidated ACCA residual clause as unconstitutionally vague)
Welch v. United States, 136 S. Ct. 1257 (2016) (held Johnson is retroactive on collateral review)
Okereke v. United States, 307 F.3d 117 (3d Cir. 2002) (§ 2255 is the presumptive remedy for federal sentence challenges)
In re Dorsainvil, 119 F.3d 245 (3d Cir. 1997) (narrow circumstances where § 2255 is inadequate and § 2241 may be available)
Cradle v. United States, 290 F.3d 536 (3d Cir. 2002) (interpreting § 2255(e) safety valve and its limited application)
Robinson v. Johnson, 313 F.3d 128 (3d Cir. 2002) (district court must transfer, not adjudicate, a successive habeas petition filed without appellate authorization)