Volume 599 U. S. Part 1 Pages 465–532

OFFICIAL REPORTS OF

THE SUPREME COURT June 22, 2023

Page Proof Pending Publication

REBECCA A. WOMELDORF reporter of decisions

NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D.C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. OCTOBER TERM, 2022 465

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JONES v. HENDRIX, WARDEN certiorari to the united states court of appeals for the eighth circuit No. 21–857. Argued November 1, 2022—Decided June 22, 2023 In 2000, the District Court for the Western District of Missouri sentenced petitioner Marcus DeAngelo Jones after he was convicted on two counts of unlawful possession of a frearm by a felon, in violation of 18 U. S. C. § 922(g)(1), and one count of making false statements to acquire a fre- arm. The Eighth Circuit affrmed Jones' convictions and sentence. Jones then fled a motion pursuant to 28 U. S. C. § 2255, which resulted in the vacatur of one of his concurrent § 922(g) sentences. Many years later, this Court held in Rehaif v. United States, 588 U. S. –––, that a defendant's knowledge of the status that disqualifes him from owning a frearm is an element of a § 922(g) conviction. Rehaif 's holding abro- gated contrary Eighth Circuit precedent applied by the courts in Jones' trial and direct appeal. Seeking to collaterally attack his remaining § 922(g) conviction based on Rehaif 's statutory holding, Jones fled a Page Proof Pending Publication petition for a writ of habeas corpus under 28 U. S. C. § 2241 in the dis- trict of his imprisonment, the Eastern District of Arkansas. The Dis- trict Court dismissed Jones' habeas petition for lack of subject-matter jurisdiction, and the Eighth Circuit affrmed. Held: Section 2255(e) does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to circumvent the Antiter- rorism and Effective Death Penalty Act of 1996's (AEDPA) restrictions on second or successive § 2255 motions by fling a § 2241 habeas petition. Pp. 471–492. (a) Congress created § 2255 as a remedial vehicle by which federal prisoners could collaterally attack their sentences by motion in the sen- tencing court, rather than by a petition for a writ of habeas corpus under § 2241 in the district of confnement. The “sole purpose” of § 2255 was to address the “serious administrative problems” created by district courts collaterally reviewing one another's proceedings without access to needed evidence and “aggravated” by the concentration of federal prisoners in certain judicial districts that therefore faced “an inordinate number of habeas corpus actions.” United States v. Hayman, 342 U. S. 205, 212–214, 219. To make this change effective, Congress generally barred federal prisoners “authorized” to fle a § 2255 motion from fling a petition under § 2241. But—in a provision of § 2255(e) now known as the saving clause—Congress preserved access to § 2241 in cases where 466 JONES v. HENDRIX

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“the remedy by motion is inadequate or ineffective to test the legality of [a prisoner's] detention.” Congress later enacted AEDPA, which, as relevant here, barred sec- ond or successive § 2255 motions unless based on either “newly discov- ered evidence,” § 2255(h)(1), or “a new rule of constitutional law,” § 2255(h)(2). Some courts faced with AEDPA's second-or-successive re- strictions held that § 2255 was “inadequate and ineffective” under the saving clause when