Jones v. Hendrix


(Slip Opinion) OCTOBER TERM, 2022 1 Syllabus NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337. SUPREME COURT OF THE UNITED STATES Syllabus JONES v. HENDRIX, WARDEN CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT No. 21–857. Argued November 1, 2022—Decided June 22, 2023 In 2000, the District Court for the Western District of Missouri sentenced petitioner Marcus DeAngelo Jones after he was convicted on two counts of unlawful possession of a firearm by a felon, in violation of 18 U. S. C. §922(g)(1), and one count of making false statements to ac- quire a firearm. The Eighth Circuit affirmed Jones’ convictions and sentence. Jones then filed a motion pursuant to 28 U. S. C. §2255, which resulted in the vacatur of one of his concurrent §922(g) sen- tences. Many years later, this Court held in Rehaif v. United States, 588 U. S. ___, that a defendant’s knowledge of the status that disqual- ifies him from owning a firearm is an element of a §922(g) conviction. Rehaif ’s holding abrogated contrary Eighth Circuit precedent applied by the courts in Jones’ trial and direct appeal. Seeking to collaterally attack his remaining §922(g) conviction based on Rehaif ’s statutory holding, Jones filed a petition for a writ of habeas corpus under 28 U. S. C. §2241 in the district of his imprisonment, the Eastern District of Arkansas. The District Court dismissed Jones’ habeas petition for lack of subject-matter jurisdiction, and the Eighth Circuit affirmed. Held: Section 2255(e) does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to circumvent the Anti- terrorism and Effective Death Penalty Act of 1996’s (AEDPA) re- strictions on second or successive §2255 motions by filing a §2241 ha- beas petition. Pp. 3–25. (a) Congress created §2255 as a remedial vehicle by which federal prisoners could collaterally attack their sentences by motion in the sentencing court, rather than by a petition for a writ of habeas corpus under §2241 in the district of confinement. The “sole purpose” of §2255 was to address the “serious administrative problems” created by dis- trict courts collaterally reviewing one another’s proceedings without 2 JONES v. HENDRIX Syllabus access to needed evidence and “aggravated” by the concentration of federal prisoners in certain judicial districts that therefore faced “an inordinate number of habeas corpus actions.” United States v. Hay- man, 342 U. S. 205, 212–214, 219. To make this change effective, Con- gress generally barred federal prisoners “authorized” to file a §2255 motion from filing a petition under §2241. But—in a provision of §2255(e) now known as the saving clause—Congress preserved access to §2241 in cases where “the …

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