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8 depend on the saving clause or proceed under §2241 “directly.” Compare Brief for Petitioner 31 and Brief for Respondent 37–38 with Brief for Court-Appointed Amicus Curiae 17–18. It is difficult to imagine a case in which this logical distinction would make any practical difference. That said, were it not for the saving clause, a literal reading of §2255(e) might be thought to bar any “application for a writ of habeas corpus in behalf of a [federal] prisoner,” §2255(e), whether or not it challenged the “sentence … imposed,” §2255(a). If nothing else, then, the saving clause guards against the danger that §2255(e) might be construed to bar manner-of-detention challenges even though they are not within §2255’s substantive scope.

In 1996, Congress enacted AEDPA, which made significant reforms to the process of federal-court postconviction review for both state and federal prisoners. Most relevant here, AEDPA strictly limited “second or successive” §2255 motions to those that “contain—

"“(1) newly discovered evidence that, if proven and viewed in light of the evidence as a whole, would be sufficient to establish by clear and convincing evidence that no reasonable factfinder would have found the movant guilty of the offense; or

“(2) a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable.” §2255(h)."

Importantly, AEDPA left the text of §2255(e) unchanged. But AEDPA’s new second-or-successive restrictions indirectly gave rise to a novel application of the saving clause.

Mere months before AEDPA’s enactment, this Court decided Bailey v. United States, 516 U. S. 137 (1995). That case interpreted the offense of “us[ing]” a firearm “during and in relation to any crime of violence or drug trafficking