Jones v. Hendrix
599 U.S. 465 (2023)
Holding & Decision
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Nature Of The Case
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Facts
Since 1948, Congress has provided that a federal prisoner who collaterally attacks his sentence ordinarily must proceed by a motion in the sentencing court under §2255, rather than by a petition for a writ of habeas corpus under §2241. Since the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), second or successive §2255 motions are barred unless they rely on either “newly discovered evidence,” §2255(h)(1), or “a new rule of constitutional law,” §2255(h)(2). In 2000, P Jones was convicted of 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 acquire a firearm, in violation of §922(a)(6). The Court of Appeals for the Eighth Circuit affirmed his convictions and sentence of 327 months’ imprisonment. P filed a timely §2255 motion to vacate, set aside, or correct his sentence, which resulted in the vacatur of one of his concurrent §922(g) sentences but no other relief. In 2019, in Rehaif v. United States, this Court held that a defendant’s knowledge of the status that disqualifies him from owning a firearm is an element of a §922(g) conviction. This holding abrogated the Eighth Circuit’s precedent, which had been applied in P's trial and direct appeal. P sought to make a new collateral attack on his remaining §922(g) conviction. Rehaif’s statutory holding did not satisfy either of §2255(h)’s gateway conditions for a second or successive §2255 motion: It was neither “newly discovered evidence,” §2255(h)(1), nor “a new rule of constitutional law,” §2255(h)(2). P then relied on §2255(e)’s “saving clause,” which provides that a federal prisoner may file a petition for a writ of habeas corpus under §2241 if-and only if-§2255’s “remedy by motion is inadequate or ineffective to test the legality of his detention.” P petitioned the district where he was imprisoned in Arkansas for a writ of habeas corpus under §2241. The District Court dismissed Jones’ habeas petition for lack of subject-matter jurisdiction, and the Eighth Circuit affirmed. P appealed.
Issues
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Rule Of Law
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Legal Analysis
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