Plain-English summary
Court rules §2255(e) saving clause does not let prisoners evade AEDPA’s successive-claim limits
The Court held that the “saving clause” in 28 U.S.C. §2255(e) does not permit federal prisoners to use habeas corpus to bring claims that are subject to AEDPA’s strict rules for second or successive §2255 motions. The decision affirms the lower court’s ruling against Marcus Deangelo Jones.
Why this matters
This decision closes a potential path for federal inmates to avoid AEDPA’s strict gatekeeping rules for second or successive collateral attacks by invoking §2255(e)’s saving clause. It reinforces the high threshold and procedural limits for repeat collateral challenges, preserving AEDPA’s framework to limit prolonged federal collateral litigation.
Who may feel it
- Federal prisoners seeking to challenge convictions after finality
- Defense attorneys handling postconviction relief
- Prosecutors and federal courts that decide habeas and §2255 motions
- Policymakers and advocates interested in postconviction procedure
Key questions
- Does 28 U.S.C. §2255(e)’s saving clause allow a federal prisoner to file a new habeas petition to raise claims that AEDPA would treat as second or successive §2255 motions?
- Can an intervening judicial decision that changes the interpretation of a criminal statute be used to convert a successive §2255 claim into a new habeas petition under the saving clause?