William Andrew Wright v. Stephen Spaulding, 939 F.3d 695

Background

William Wright, a felon convicted in Maryland for possession with intent to distribute, was classified as an Armed Career Criminal based on three prior "serious drug offenses" and received the 15-year ACCA minimum; he did not appeal.
Years later Wright moved under 28 U.S.C. § 2255 (after Johnson) and was denied because Johnson invalidated the ACCA residual clause (violent-felony focus), not his drug-predicate-based enhancement.
After Mathis clarified the categorical approach to ACCA predicates, Wright filed a § 2241 habeas petition in his district of confinement (Northern District of Ohio) invoking the § 2255(e) "saving clause"; the district court dismissed and Wright appealed.
Historically, § 2255 redirected sentence challenges to the sentencing court, but a § 2255(e) saving clause preserved § 2241 when § 2255 was "inadequate or ineffective," a narrow exception courts expanded post-Bailey/AEDPA for defendants who had "no reasonable opportunity" to raise newly available statutory-interpretation claims because of binding adverse precedent.
The Sixth Circuit adheres to the limiting rule: a petitioner seeking § 2241 via the saving clause must show he had no reasonable earlier opportunity to raise the claim (at sentencing, on direct appeal, or in an initial § 2255); Wright failed to show that here and thus cannot obtain § 2241 relief.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wright may invoke § 2255(e) saving clause to pursue a § 2241 petition based on Mathis	Mathis made available a substantive categorical-approach argument showing his Maryland conviction was not an ACCA predicate, so § 2255 was inadequate and § 2241 is proper	§ 2255 was adequate because Wright had prior opportunities (sentencing, direct appeal, initial § 2255) to raise the categorical-approach claim; Mathis did not create a unique obstacle	Denied: Wright lacked the required showing that he had "no reasonable opportunity" earlier to raise the claim, so § 2255 was not inadequate and § 2241 is unavailable
Whether Hill v. Masters altered the Sixth Circuit’s "no reasonable opportunity" requirement for savings-clause access	Wright suggested Hill’s wording adopted a broader three-part test that might relax the reasonable-opportunity requirement	Government argued Hill did not eliminate the reasonable-opportunity requirement and its contested language was not the binding holding	Held: Hill did not change the requirement; its holding was narrower and did not decide the availability issue because the government conceded earlier opportunity in Hill
Whether courts should treat party concessions or unconsidered assumptions as binding precedent	Wright relied on broader readings of prior panels; he argued some panels created binding tests	Government argued courts must follow binding holdings only, not dicta or unconsciously adopted concessions	Held: Binding precedent is limited to holdings; courts should not treat concessions or unexamined assumptions as binding—only conclusions necessary to the judgment bind later panels

Key Cases Cited

Mathis v. United States, 136 S. Ct. 2243 (2016) (clarified use of the categorical approach to determine ACCA predicate offenses)
Johnson v. United States, 135 S. Ct. 2551 (2015) (struck down ACCA residual clause as unconstitutionally vague)
Bailey v. United States, 516 U.S. 137 (1995) (interpreted the scope of "use" of a firearm, prompting circuit reversals)
Hayman v. United States, 342 U.S. 205 (1952) (explained § 2255 relocated venue for sentence challenges to the sentencing court)
Felker v. Turpin, 518 U.S. 651 (1996) (noted that Congress normally, not courts, sets the scope of habeas relief)
In re Dorsainvil, 119 F.3d 245 (3d Cir. 1997) (recognized saving-clause access where petitioner had no earlier opportunity to raise the claim)
Triestman v. United States, 124 F.3d 361 (2d Cir. 1997) (adopted a similar saving-clause workaround for procedurally barred claims)
In re Davenport, 147 F.3d 605 (7th Cir. 1998) (held § 2255 inadequate where binding precedent foreclosed an earlier challenge—"no reasonable opportunity")
Martin v. Perez, 319 F.3d 799 (6th Cir. 2003) (Sixth Circuit applied the no-reasonable-opportunity saving-clause approach)
Hill v. Masters, 836 F.3d 591 (6th Cir. 2016) (applied a three-part test for savings-clause claims but did not decide availability because of parties’ concessions)
Prost v. Anderson, 636 F.3d 578 (10th Cir. 2011) (examined the saving clause and AEDPA interaction; noted circuit split and limits of judicially created workarounds)
United States v. Washington, 629 F.3d 403 (4th Cir. 2011) (applied the modified categorical approach to Maryland possession-with-intent statute; identified as binding in Wright’s context)