This page has been proofread, but needs to be validated.
14
JONES v. HENDRIX

Opinion of the Court

a broad range of circumstances, we find this excursus irrelevant to the question presented here. To the extent that Congress’ use of “inadequate” in the saving clause harkens back to equity’s historic use of that term (an issue we need not address), the most Jones’ evidence proves is that a variety of circumstances might make it impracticable for a prisoner to seek relief from the sentencing court. Cf. Hayman, 342 U. S., at 215, n. 23. Nothing in Jones’ survey of equity jurisprudence, however, even begins to suggest that the saving clause offers an exemption from AEDPA’s clear limits on second or successive collateral attacks.

Trying a different tack, Jones suggests that the saving clause’s use of the present tense (“is inadequate or ineffective”) means that §2241 is available whenever a prisoner is presently unable to file a §2255 motion. Even the Circuits with an expansive view of the saving clause have uniformly rejected this argument, and for good reason. See, e.g., In re Jones, 226 F. 3d, at 333; Dorsainvil, 119 F. 3d, at 251. Were this argument accepted, AEDPA’s changes to §2255 would be entirely futile, as §2241 would be available any time the second-or-successive restrictions precluded relief. We decline to infer that Congress intended AEDPA’s carefully crafted limits on collateral relief under §2255 to be mere nullities.

As a backstop to his scattershot textual arguments, Jones invokes the constitutional-doubt canon, arguing that denying him the chance to raise his Rehaif claim in a §2241 petition raises serious constitutional questions. It does not.[1]


  1. As Court-appointed amicus curiae observes, Jones’ use of the constitutional-doubt canon is somewhat anomalous, in that it aims at a different result from what a direct constitutional challenge would achieve. If a prisoner persuaded a court that the exclusion of statutory claims from §2255(h) was unconstitutional, the result would not be that he could proceed under §2241, but simply that he could file a second or successive §2255 motion on an equal footing with §§2255(h)(1) and 2255(h)(2) claims.