Page:Jones v. Hendrix.pdf/36

4 (1952). Such petitions sought judicial review of the legality of the individual’s detention, and were filed in the district where the person was incarcerated. Ibid. This led to some problems: Districts that housed large federal prisons were disproportionately burdened with habeas petitions. Id., at 213–214. Also, in many cases, the court deciding the petition was both unfamiliar with the underlying facts and far away from the relevant record, evidence, and witnesses. Ibid.

Congress created §2255—an entirely new process for federal prisoners to use when seeking postconviction judicial review—to solve these practical problems. Under the procedures laid out in §2255, in lieu of filing a traditional habeas petition, federal prisoners must file a §2255 motion. And any such motion is to be filed in the sentencing court, not in the district of confinement. §2255(a) (2018 ed.); see Hayman, 342 U. S., at 219.

Congress crafted (what is now) §2255(e) to ensure that the new §2255 procedure successfully ousted the outdated habeas regime it replaced. Per the first part of that provision, as a general matter, §2255 becomes the exclusive procedure by which federal prisoners can collaterally attack their convictions. See §2255(e) (providing that “[a]n application for a writ of habeas corpus … shall not be entertained” where, in essence, the prisoner fails to bring an authorized §2255 motion, or does so and is denied relief). Yet Congress also specified that, in a circumstance in which §2255 is “inadequate or ineffective to test the legality of his detention,” an individual could still file a habeas petition. Ibid.

There are multiple ways in which §2255 might be “insufficient” or “[n]ot capable of performing the required work” of postconviction review of federal convictions. Webster’s New International Dictionary 1254, 1271 (2d ed. 1934) (defining “inadequate” and “ineffective” in this manner); see