Jones v. Hendrix

Marcus Jones (plaintiff) was imprisoned for two violations of 18 U.S.C. § 922(g), a gun law. Jones collaterally attacked his convictions and had one of his two concurrent sentences vacated. Jones mounted his attack under 28 U.S.C. § 2255, an alternative to habeas corpus that Congress had enacted in 1948 to alleviate administrative problems inherent in the federal habeas corpus statute, 28 U.S.C. § 2241. Section 2255(e)’s saving clause preserved an inmate’s right to petition for § 2241 relief if the remedies provided by § 2255 proved inadequate or ineffective. Jones might have invoked § 2255 a second time, after a 2019 United States Supreme Court decision redefined and arguably removed the statutory underpinnings for Jones’s § 922(g) convictions. However, the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) had made this impossible by adding § 2255(h), a clause that prohibited successive § 2255 motions except in limited circumstances that were inapplicable to Jones’s case. Jones claimed that because § 2255 no longer furnished an adequate or effective basis for challenging his conviction, § 2255(e) empowered Jones to file a § 2241 habeas corpus petition against warden Dwayne Hendrix (defendant). The district-court judgment rejecting Jones’s § 2241 petition was affirmed by the Eighth Circuit. Jones appealed to the Supreme Court.