They could also include challenges to the conditions of detention, rather than the legality of the sentence. The court held that the historical understanding of the saving clause is limited to “unusual circumstances in which it is impossible or impracticable for a prisoner to seek relief from the sentencing court.” These circumstances included situations in which the sentencing court had been dissolved or the prisoner otherwise could not be transported there – the saving clause, Thomas noted, was enacted before the construction of the Interstate Highway System. Jones accordingly argued that the saving clause permitted him to file a habeas petition, because Section 2255’s bar on second and successive petitions rendered the motion to vacate an “inadequate or ineffective” vehicle to challenge his detention.īy a vote of 6-3, the Supreme Court disagreed.
But he had already long ago filed and lost his Section 2255 motion and was therefore barred under AEDPA from bringing another one. The Rehaif decision established that Jones was legally innocent based on the court’s interpretation of the felon-in-possession statute. United States that the government had to prove that the defendant knew he was an unlawful possessor of a firearm, an element not proven at Jones’s trial. Nearly two decades later, the Supreme Court decided in Rehaif v.
Jones was convicted in 2000 of being a felon in possession of a firearm and sentenced to over 27 years in prison. This statutory past is prologue to the case of Marcus DeAngelo Jones. That law restricted prisoners’ ability to bring “second or successive” motions to vacate under Section 2255, effectively giving them one bite at the apple to challenge a conviction, except under two circumstances: (1) when newly discovered evidence would be sufficient to establish that no reasonable factfinder would have found the person guilty and (2) when a new rule of constitutional law, which was previously unavailable, was made retroactive by the Supreme Court. The statute replaced the habeas remedy with the motion to vacate, unless the “remedy by motion is inadequate or ineffective to test the legality of detention.” This provision, known as the “saving clause,” preserved habeas for those prisoners.įast forward to 1996: In the wake of the Oklahoma City bombing, Congress passed AEDPA. § 2255, which routed all habeas petitions into a “motion to vacate” the conviction or sentence, to be filed in the original sentencing court.
That setup had practical problems: It meant that districts with larger numbers of prisoners were inundated with habeas petitions, and it was sometimes difficult to obtain the court record from the district where the person had been convicted and sentenced. To understand that decision, a bit of statutory history is needed: Prior to 1948, federal prisoners could challenge their convictions through a petition for a writ of habeas corpus – the “Great Writ” that traces its origins to the Magna Carta – in the judicial district in which they were imprisoned. It is the latest in a string of cases construing AEDPA in which the court has held, as Justice Clarence Thomas put it in his majority opinion, that “Congress has chosen finality over error correction.” Hendrix turns on the interpretation of the federal habeas statute, as amended by the Anti-Terrorism and Effective Death Penalty Act of 1996. On Thursday, the Supreme Court held that a federal prisoner cannot raise a claim of legal innocence if he has already challenged his conviction – even if that claim was unavailable at the time he filed his challenge.
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