Taylor v. Krueger, 1:17-cv-01143

In 1996 Anthony Taylor was convicted of crack-cocaine offenses and sentenced as a career offender to 360 months imprisonment under U.S. Sentencing Guidelines §4B1.1.
Taylor’s first 28 U.S.C. §2255 motion (filed 1998) was denied and the denial was affirmed on appeal.
In 2015 Taylor sought a sentence reduction under Amendment 782; the district court denied relief and allowed supplemental briefing after Johnson v. United States.
The Seventh Circuit authorized Taylor to file a second §2255 based on Johnson; in that §2255 Taylor argued his Illinois aggravated battery and burglary convictions did not qualify as career-offender predicates under Mathis.
The district court denied the second §2255 in September 2016 after applying Mathis and concluding both prior convictions qualified as crimes of violence; Taylor’s motion for reconsideration was denied and he appealed.
In April 2017 Taylor filed a §2241 habeas petition arguing Mathis precludes his aggravated battery conviction from qualifying as a career-offender predicate; the district court dismissed the §2241 petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Taylor may proceed under 28 U.S.C. §2241 via the §2255 "savings clause" based on Mathis	Taylor: Mathis changed the law so his Illinois aggravated battery conviction no longer qualifies as a career-offender predicate, so §2255 is inadequate and §2241 is available	Respondent: Taylor already raised Mathis-style arguments in his authorized second §2255, so he cannot use §2241; §2255 remains the correct remedy	Denied — Taylor cannot meet Davenport’s savings-clause requirements because Mathis-based arguments were available and were raised in his prior §2255, so §2241 relief is unavailable

Johnson v. United States, 135 S. Ct. 2551 (2015) (interpreting the ACCA residual clause and prompting collateral challenges)
Mathis v. United States, 136 S. Ct. 2243 (2016) (method for determining whether a prior conviction qualifies as a predicate under categorical approach)
Brown v. Rios, 696 F.3d 638 (7th Cir. 2012) (§2255 is the usual vehicle for federal prisoners to attack sentences)
In re Davenport, 147 F.3d 605 (7th Cir. 1998) (established conditions for invoking the §2255 savings clause)
Brown v. Caraway, 719 F.3d 583 (7th Cir. 2013) (summarized Davenport’s three-part test for savings-clause relief)
Poe v. United States, 468 F.3d 473 (7th Cir. 2006) (procedural rules regarding habeas petitions)
Hudson v. Helman, 948 F. Supp. 810 (C.D. Ill. 1996) (applying Rule 4 of the Rules Governing Section 2254 Cases to §2241 practice)