Jones v. Hendrix

A prisoner may not proceed under the general habeas corpus statute simply because of limitations imposed on filing additional alternative postconviction remedy motions. 28 U.S.C. §§ 2241, 2255(h)(1)-(2).

Jones was convicted in district court for multiple gun charges. 18 U.S.C. §§ 922(g)(1), (a)(6). Following one successful claim for relief under 28 U.S.C. § 2255, statutory precedent used to convict him changed, so Jones filed a new claim for relief under the general habeas corpus statute, 28 U.S.C. § 2241. The district court dismissed his claims, and the Eighth Circuit affirmed. Federal prisoners are required to file habeas claims using the alternative postconviction remedy, section 2255, and not the general habeas statute, section 2241, unless the section 2255 remedy is “inadequate or ineffective to test the legality of [their] detention.” 28 U.S.C. §§ 2241, 2255(e). On appeal, the Court held that a prisoner may not proceed under the general habeas corpus statute simply because of limitations imposed on filing additional alternative postconviction remedy motions. Section 2255 specifies when “second or successive” collateral attacks on a prisoner’s sentence are allowed, “newly discovered evidence” or “new rule of constitutional law,” implying that Congress did not intend new readings of statutory law to qualify. §§ 2255(h)(1)-(2). Reading sections 2255 and 2241 in harmony, section 2255(e)’s funnel to the general habeas statute applies only to unusual cases where the section 2255 motion is impossible or impracticable to seek relief, like the sentencing court dissolving or a petitioner’s inability to appear. See, e.g., Witham v. United States, 355 F. 3d 501, 504–505 (CA6 2004); see also United States v. Hayman, 342 U. S. 205, 215, n. 23 (1952). Affirmed.