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Jones v. Hendrix

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Supreme Court of the United States
Jones v. Hendrix
Term: 2022
Important Dates
Argued: November 1, 2022
Decided: June 22, 2023
Outcome
Pending
Vote
6-3
Majority
Clarence Thomas • Chief Justice John Roberts • Samuel Alito • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Dissenting
Sonia Sotomayor • Elena Kagan • Ketanji Brown Jackson

Jones v. Hendrix is a case that was decided by the Supreme Court of the United States on June 22, 2023, during the court's October 2022-2023 term. The case was argued before the court on November 1, 2022.

The court affirmed the decision of the U.S. Court of Appeals for the Eighth Circuit in a 6-3 ruling, holding "[s]ection 2255(e) does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to circumvent the Antiterrorism and Effective Death Penalty Act of 1996’s (AEDPA) restrictions on second or successive §2255 motions by filing a §2241 habeas petition."[1] Justice Clarence Thomas delivered the majority opinion of the court. Justice Sonia Sotomayor filed a dissenting opinion, joined by Justice Elena Kagan. Justice Ketanji Brown Jackson also filed a dissenting opinion.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: In 2000, Marcus Jones was convicted of possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). He repeatedly challenged his conviction in U.S. district and circuit courts, including in the Eighth Circuit. The courts consistently denied his petitions. In 2019, the U.S. Supreme Court ruled in Rehaif v. United States (2019) that to convict someone under 18 U.S.C. § 922, the government must prove that the defendant knew that it was illegal for him or her to carry a firearm and that he or she possessed a firearm. Rehaif (2019) overturned the Eighth Circuit's approach to Jones' case. As a result, Jones challenged his conviction again. The district court and the Eighth Circuit dismissed his challenge. Click here to learn more about the case's background.
  • The issue: The case concerned the means for federal inmates to challenge the legality of their convictions per 28 U.S.C. § 2255 and habeas corpus.
  • The questions presented: "Whether a district court has the power to review a claim that a federal prisoner’s sentence is invalid based on a Supreme Court decision."[2]
  • The outcome: The court affirmed the judgment of the U.S. Court of Appeals for the Eighth Circuit, holding "[s]ection 2255(e) does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to circumvent the Antiterrorism and Effective Death Penalty Act of 1996’s (AEDPA) restrictions on second or successive §2255 motions by filing a §2241 habeas petition."[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Eighth Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    In 2000, Marcus Jones was convicted on two counts of possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). Jones filed a petition in the United States District Court for the Eastern District of Arkansas for a writ of habeas corpus, challenging his conviction. The district court denied the motion, holding Jones had not followed proper procedure under 28 U.S.C. § 2255. Jones appealed, and the U.S. Court of Appeals for the Eighth Circuit reversed the lower court's opinion and remanded the case. On remand, the Eastern District of Arkansas vacated one of Jones' felon-in-possession convictions, resentenced Jones, and denied his request for a new sentencing hearing. Jones appealed again and the Eighth Circuit affirmed the lower court's judgment. From 2006 to date, Jones filed multiple post-conviction challenges and several petitions for a writ of certiorari to the U.S. Supreme Court. The motions were consistently denied.[3]

    In 2019, the U.S. Supreme Court ruled in Rehaif v. United States (2019) that to convict someone under 18 U.S.C. § 922, the government must prove that the defendant knew that it was illegal for him or her to carry a firearm and that he or she possessed a firearm. Rehaif (2019) overturned the Eighth Circuit's approach to Jones' case. Jones thus challenged his conviction under Rehaif (2019). The district court and the Eighth Circuit held Jones could not proceed with a habeas corpus petition because he had not adequately shown that § 2255 was inadequate or ineffective.[3] Jones appealed to the U.S. Supreme Court.

    28 U.S.C. § 2255

    28 U.S.C. § 2255 allows federal inmates to challenge their sentences or convictions "upon the ground that the sentence was imposed in violation of the Constitution or laws of the United States, or that the court was without jurisdiction to impose such sentence, or that the sentence was in excess of the maximum authorized by law, or is otherwise subject to collateral attack."

    Titled "Federal custody; remedies on motion attacking sentence," § 2255 holds:

    (a) A prisoner in custody under sentence of a court established by Act of Congress claiming the right to be released upon the ground that the sentence was imposed in violation of the Constitution or laws of the United States, or that the court was without jurisdiction to impose such sentence, or that the sentence was in excess of the maximum authorized by law, or is otherwise subject to collateral attack, may move the court which imposed the sentence to vacate, set aside or correct the sentence.

    (b) Unless the motion and the files and records of the case conclusively show that the prisoner is entitled to no relief, the court shall cause notice thereof to be served upon the United States attorney, grant a prompt hearing thereon, determine the issues and make findings of fact and conclusions of law with respect thereto. If the court finds that the judgment was rendered without jurisdiction, or that the sentence imposed was not authorized by law or otherwise open to collateral attack, or that there has been such a denial or infringement of the constitutional rights of the prisoner as to render the judgment vulnerable to collateral attack, the court shall vacate and set the judgment aside and shall discharge the prisoner or resentence him or grant a new trial or correct the sentence as may appear appropriate.

    (c) A court may entertain and determine such motion without requiring the production of the prisoner at the hearing.

    (d) An appeal may be taken to the court of appeals from the order entered on the motion as from a final judgment on application for a writ of habeas corpus.

    (e) An application for a writ of habeas corpus in behalf of a prisoner who is authorized to apply for relief by motion pursuant to this section, shall not be entertained if it appears that the applicant has failed to apply for relief, by motion, to the court which sentenced him, or that such court has denied him relief, unless it also appears that the remedy by motion is inadequate or ineffective to test the legality of his detention.

    (f) A 1-year period of limitation shall apply to a motion under this section. The limitation period shall run from the latest of—

    (1) the date on which the judgment of conviction becomes final;
    (2) the date on which the impediment to making a motion created by governmental action in violation of the Constitution or laws of the United States is removed, if the movant was prevented from making a motion by such governmental action;
    (3) the date on which the right asserted was initially recognized by the Supreme Court, if that right has been newly recognized by the Supreme Court and made retroactively applicable to cases on collateral review; or
    (4) the date on which the facts supporting the claim or claims presented could have been discovered through the exercise of due diligence.

    (g) Except as provided in section 408 of the Controlled Substances Act, in all proceedings brought under this section, and any subsequent proceedings on review, the court may appoint counsel, except as provided by a rule promulgated by the Supreme Court pursuant to statutory authority. Appointment of counsel under this section shall be governed by section 3006A of title 18.

    (h) A second or successive motion must be certified as provided in section 2244 by a panel of the appropriate court of appeals to contain—

    (1) newly discovered evidence that, if proven and viewed in light of the evidence as a whole, would be sufficient to establish by clear and convincing evidence that no reasonable factfinder would have found the movant guilty of the offense; or
    (2) a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable.

    Questions presented

    The petitioner presented the following question to the court:

    Question presented:
    “ The question presented is whether federal inmates who did not—because established circuit precedent stood firmly against them—challenge their convictions on the ground that the statute of conviction did not criminalize their activity may apply for habeas relief under § 2241 after this Court later makes clear in a retroactively applicable decision that the circuit precedent was wrong and that they are legally innocent of the crime of conviction.

    [4]

    		”

    Oral argument

    Audio

    Audio of oral argument:[5]



    Transcript

    Transcript of oral argument:[6]


    Outcome

    In a 6-3 opinion, the court affirmed the judgment of the U.S. Court of Appeals for the Eighth Circuit, holding "[s]ection 2255(e) does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to circumvent the Antiterrorism and Effective Death Penalty Act of 1996’s (AEDPA) restrictions on second or successive §2255 motions by filing a §2241 habeas petition."[1] Justice Clarence Thomas delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Clarence Thomas wrote:[1]

    “

    [T]here is no historical or constitutional norm of permitting one convicted of a crime by a court of competent jurisdiction to collaterally attack his sentence based on an alleged error of substantive statutory law. As far as history and the Constitution are concerned, “there is nothing incongruous about a system in which this kind of error—the application of a since-rejected statutory interpretation—cannot be remedied after final judgment.” George v. McDonough, 596 U. S. ___, ___ (2022) (slip op., at 10). A fortiori, there is nothing fundamentally surprising about Congress declining to make such errors remediable in a second or successive collateral attack. [4]

    		”
    —Justice Clarence Thomas

    Sotomayor's dissenting opinion

    Justice Sonia Sotomayor filed a dissenting opinion, joined by Justice Elena Kagan.

    In her dissent, Justice Sotomayor wrote:[1]

    “

    A prisoner who is actually innocent, imprisoned for conduct that Congress did not criminalize, is forever barred by 28 U. S. C. §2255(h) from raising that claim, merely because he previously sought postconviction relief. It does not matter that an intervening decision of this Court confirms his innocence. By challenging his conviction once before, he forfeited his freedom. [4]

    		”
    —Justice Sonia Sotomayor

    Jackson's dissenting opinion

    Justice Ketanji Brown Jackson also filed a dissenting opinion.

    In her dissent, Justice Jackson wrote:[1]

    “

    I am also deeply troubled by the constitutional implications of the nothing-to-see-here approach that the majority takes with respect to the incarceration of potential legal innocents. See Part III, infra. Apparently, legally innocent or not, Jones must just carry on in prison regardless, since (as the majority reads §2255) no path exists for him to ask a federal judge to consider his innocence assertion. But forever slamming the courtroom doors to a possibly innocent person who has never had a meaningful opportunity to get a new and retroactively applicable claim for release reviewed on the merits raises serious constitutional concerns. [4]

    		”
    —Justice Ketanji Brown Jackson

    Text of the opinion

    Read the full opinion here.

    October term 2022-2023

    See also: Supreme Court cases, October term 2022-2023

    The Supreme Court began hearing cases for the term on October 3, 2022. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[7]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 SUPREME COURT OF THE UNITED STATES, "JONES v. HENDRIX, WARDEN," June 22, 2023
    2. ↑ SCOTUSblog, "Justices grant review in two cases that test jurisdiction of district courts," May 16, 2022
    3. ↑ 3.0 3.1 Supreme Court of the United States, Jones v. Hendrix, "Petition for a writ of certiorari," December 7, 2021
    4. ↑ 4.0 4.1 4.2 4.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    5. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued November 1, 2022
    6. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued November 1, 2022
    7. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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