Supreme Court Cases

 

Jones v. Hendrix

Docket: 21-857 Decision Date: 2023-06-22
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This links to the official slip opinion PDF.
How to read this page

Below are plain-language sections to help you understand what the Court decided in Jones v. Hendrix and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).

Summary

A short, plain-English overview of Jones v. Hendrix.

In Jones v. Hendrix, the Supreme Court addressed whether a federal prisoner could use a § 2241 habeas petition to challenge a conviction based on an intervening change in statutory interpretation, circumventing the restrictions of the Antiterrorism and Effective Death Penalty Act of 1996. The Court affirmed the lower courts' decisions, emphasizing the limitations imposed by § 2255 on second or successive motions. The decision clarified that the saving clause of § 2255(e) does not permit such an end-run around AEDPA's restrictions.

Holding

The single most important “bottom line” of what the Court decided in Jones v. Hendrix.

The Court held that Section 2255(e) does not allow a prisoner to circumvent AEDPA's restrictions on second or successive § 2255 motions by filing a § 2241 habeas petition.

Constitutional Concepts

These are the Constitution-related themes that appear in Jones v. Hendrix. Click a concept to see other cases that involve the same idea.

  • Why Procedural Due Process is relevant to Jones v. Hendrix

    The case involves the procedural mechanism by which federal prisoners can challenge their detention, specifically the adequacy of § 2255 as a remedy.

    Syllabus excerpt (verbatim)
    The saving clause preserves recourse to § 2241 in cases where unusual circumstances make it impossible or impracticable to seek relief in the sentencing court.
  • Why Substantive Due Process is relevant to Jones v. Hendrix

    The case touches on substantive due process in the context of the legality of detention and the interpretation of criminal statutes.

    Syllabus excerpt (verbatim)
    Jones argues that denying him a new opportunity for collateral review of his Rehaif claim threatens Congress' exclusive power to define crimes.

Key Quotes

Short excerpts from the syllabus in Jones v. Hendrix that support the summary and concepts above.

  • Section 2255(e)'s saving clause does not authorize that end-run around AEDPA.
  • The inability of a prisoner with a statutory claim to satisfy § 2255(h) does not mean that the prisoner may bring the claim in a § 2241 petition.
  • AEDPA's restrictions embody Congress' policy judgment regarding the appropriate balance between finality and error correction.

 

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