Jones v. Hendrix

In Jones v. Hendrix, petitioner Marcus DeAngelo Jones, a federal prisoner in Missouri, was convicted of being a felon in possession of a firearm and making false statements to acquire a firearm. His first motion under 28 U.S.C. §2255 was denied. After the Supreme Court's 2019 decision in Rehaif v. United States required the government to prove a defendant knew his prohibited status, Jones claimed actual innocence and sought habeas relief under §2241, arguing that §2255's saving clause applied because his remedy was inadequate. The Eighth Circuit rejected his petition. The Supreme Court affirmed, ruling that the saving clause does not permit a federal prisoner to use §2241 to bring a claim that would be a second or successive §2255 motion, even if a new statutory interpretation supports factual innocence.

In a 6-3 decision authored by Justice Clarence Thomas, the Supreme Court affirmed the Eighth Circuit and held that the saving clause does not authorize Jones's petition; his remedy was barred.

Whether a federal prisoner who previously filed an unsuccessful §2255 motion may resort to §2241 through the saving clause to assert actual innocence based on a new Supreme Court statutory ruling.

The ruling limits post-conviction review for federal prisoners, even where new law suggests innocence. It reinforces finality over innocence claims. Dissenting justices argued it leaves some prisoners with no meaningful remedy for unconstitutional convictions.