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 remedy by motion is inadequate or inef- fective to test the legality of [a prisoner’s] detention.” Congress later enacted AEDPA, which, as relevant here, barred sec- ond or successive §2255 motions unless based on either “newly discov- ered evidence,” §2255(h)(1), or “a new rule of constitutional law,” §2255(h)(2). Some courts faced with AEDPA’s second-or-successive re- strictions held that §2255 was “inadequate and ineffective” under the saving clause when AEDPA’s restrictions barred a prisoner from seek- ing relief based on a new interpretation of a criminal statute that cir- cuit precedent had foreclosed at the time of the prisoner’s trial, appeal, and first §2255 motion. Section 2255(e)’s saving clause does not authorize that end-run around AEDPA. The clause preserves recourse to §2241 in cases where unusual circumstances make it impossible or impracticable to seek re- lief in the sentencing court, as well as for challenges to detention other than collateral attacks on a sentence. But §2255(h) specifies the two limited conditions in which federal prisoners may bring second or suc- cessive collateral attacks on their sentences. The inability of a pris- oner with a statutory claim to satisfy §2255(h) does not mean that the prisoner may bring the claim in a §2241 petition. Pp. 3–12. (b) Jones and the United States each advance unpersuasive theories of when and why §2255(h)’s exclusion of statutory claims sometimes renders §2255 inadequate or ineffective for purposes of the saving clause. Pp. 12–25. (1) Jones argues that §2255 is necessarily “inadequate or ineffec- tive to test” a prisoner’s claim if the §2255 court fails to apply the cor- rect substantive law. But the saving clause is concerned with the ad- equacy or effectiveness of the remedial vehicle (“the remedy by motion”), not any court’s asserted errors of law. Next, Jones argues that courts of equity would afford relief from “inadequate” legal reme- dies in a broad range of circumstances; to the extent relevant to §2255(e), this proves at most that a variety of practical obstacles might trigger the saving clause, cf. Hayman, 342 U. S., at 215, n. 23, not that the clause offers an exemption from AEDPA’s limits on second or suc- cessive collateral attacks. Jones further argues that the saving clause’s use of the present tense (“is inadequate or ineffective”) means that §2241 is available whenever a prisoner is presently unable to file Cite as: 599 U. S. ____ (2023) 3 Syllabus a §2255 motion. That argument would nullify AEDPA’s limits on col- lateral relief. Jones suggests that denying him the chance to raise his Rehaif claim in a §2241 petition would violate the Suspension Clause, U. S. Const., Art. I, §9, cl. 2. This argument fails because it would extend the writ of habeas corpus far beyond its scope when the Constitution was drafted and ratified. Department of Homeland Security v. Thuraissi- giam, 591 U. S. ___, ___. When the Suspension Clause was adopted, Jones’ Rehaif claim would not have been cognizable in habeas at all. At the founding, a sentence after conviction “by a court of competent jurisdiction” was “ ‘in itself sufficient cause’ ” for a prisoner’s continued detention. Brown v. Davenport, 596 U. S. ___, ___ (quoting Ex parte Watkins, 3 Pet. 193, 202). Of particular relevance here, a habeas court had no power to “look beyond the judgment” to “re-examine the charges on which it was rendered” for substantive errors of law—even “if . . . the [sentencing] court ha[d] misconstrued the law, and ha[d] pro- nounced an offence to be punishable criminally, which [was] not so.” Id., at 202, 209. While Jones argues that pre-founding practice was otherwise, he fails to identify a single clear case of habeas being used to relitigate a conviction after trial by a court of general criminal juris- diction. The principles of Ex parte Watkins guided this Court’s understand- ing of the habeas writ throughout the 19th century and well into the 20th. See Brown, 596 U. S., at ___, n. 1 (collecting cases). It was not until 1974, in Davis v. United States, 417 U. S. 333, that the Court held for the first time that a substantive error of statutory law could be a cognizable ground for a collateral attack on a federal court’s criminal judgment. See id., at 342–347. The Suspension Clause neither consti- tutionalizes that innovation nor requires its extension to a second or successive collateral attack. Jones’ remaining constitutional arguments are no more persuasive. He argues that denying him a new opportunity for collateral review of his Rehaif claim threatens Congress’s exclusive power to define crimes, but a court does not usurp legislative power simply by misinterpreting the law in a given case. Next, Jones points to Fiore v. White, 531 U. S. 225 (per curiam), which applied the rule that due process requires that the prosecution prove every element of a crime beyond a reasonable doubt. But due process d