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Rh crime,” in violation of then-existing 18 U. S. C. §924(c)(1), more narrowly than many Circuits’ previous case law. See 516 U. S., at 142 (describing the Circuits’ approaches). Under this Court’s §2255 precedent, Bailey’s narrowing interpretation was grounds for a collateral attack by federal prisoners who had been convicted under the Courts of Appeals’ broader interpretations. See Davis, 417 U. S., at 342–347 (holding a claim of legal error based on an intervening change in statutory interpretation cognizable under §2255). Many prisoners with Bailey claims, however, had already exhausted their first §2255 motion, and Bailey’s statutory holding plainly did not satisfy either of §2255(h)’s conditions for a second or successive motion.

Several Courts of Appeals found a workaround for those prisoners in the saving clause. With minor differences in reasoning and wording, they held that §2255 was “inadequate and ineffective” under the saving clause—and that §2241 was therefore available—when AEDPA’s second-or-successive restrictions barred a prisoner from seeking relief based on a newly adopted narrowing interpretation of a criminal statute that circuit precedent had foreclosed at the time of the prisoner’s trial, appeal, and first §2255 motion. This application of the saving clause took shape in In re Dorsainvil, 119 F. 3d 245, 251 (CA3 1997); Triestman v. United States, 124 F. 3d 361, 378–380 (CA2 1997); and In re Davenport, 147 F. 3d 605, 609–611 (CA7 1998), and it was later adopted by most of the other Circuits. See Ivy v. Pontesso, 328 F. 3d 1057, 1059–1060 (CA9 2003); Martin v. Perez, 319 F. 3d 799, 804–805 (CA6 2003); Reyes–Requena v. United States, 243 F. 3d 893, 904 (CA5 2001); In re Jones, 226 F. 3d 328, 333–334 (CA4 2000); Wofford v. Scott, 177 F. 3d 1236, 1242–1245 (CA11 1999), overruled by McCarthan v. Director of Goodwill Industries–Suncoast, Inc., 851 F. 3d 1076 (CA11 2017) (en banc); but see Prost v. Anderson, 636 F. 3d 578, 584–595 (CA10 2011) (Gorsuch, J.) (holding