Page:Jones v. Hendrix.pdf/8

Rh §2255(e)’s “saving clause,” which provides that a federal prisoner may file a petition for a writ of habeas corpus under §2241 if—and only if—§2255’s “remedy by motion is inadequate or ineffective to test the legality of his detention.” Invoking this clause, Jones petitioned the U. S. District Court for the Eastern District of Arkansas, the district where he was imprisoned, for a writ of habeas corpus under §2241.

The District Court dismissed Jones’ habeas petition for lack of subject-matter jurisdiction, and the Eighth Circuit affirmed. 8 F. 4th 683 (2021). The Eighth Circuit rejected Jones’ argument that the saving clause permits recourse to §2241 to present a §2255(h)-barred claim based on an intervening decision of statutory interpretation, as well as his argument that foreclosing relief on his Rehaif claim would violate the Suspension Clause, U. S. Const., Art. I, §9, cl. 2. In doing so, the Eighth Circuit deepened a split among the Courts of Appeals about whether prisoners in Jones’ circumstances may resort to §2241 via the saving clause.

We granted certiorari. 596 U. S. ___ (2022). The Solicitor General then noticed her intent to defend the Eighth Circuit’s judgment but not its rationale. We appointed Morgan Ratner as amicus curiae to argue in support of the Eighth Circuit’s reasoning. 597 U. S. ___ (2022). She has ably discharged her responsibilities.

Consistent with the Eighth Circuit’s reasoning, we hold that §2255(e)’s saving clause does not permit a prisoner asserting an intervening change in statutory interpretation to circumvent AEDPA’s restrictions on second or successive §2255 motions by filing a §2241 petition. We begin by considering the role of the saving clause in §2255 prior to AEDPA’s enactment. We then consider the impact of AEDPA on the statutory scheme.