Jones v. Hendrix

The Court ruled that federal prisoners cannot use a habeas corpus petition (a court challenge to detention) to bypass limits on repeat post-conviction motions based on a later interpretation of a criminal law. It affirmed the Eighth Circuit, 6-3.

The Court ruled 6-3. Justice Clarence Thomas wrote the majority opinion, joined by Chief Justice John Roberts and Justices Samuel Alito, Neil Gorsuch, Brett Kavanaugh, and Amy Coney Barrett; Justices Sonia Sotomayor, Elena Kagan, and Ketanji Brown Jackson each wrote dissents.

Majority

Thomas

Roberts

Alito

Gorsuch

Kavanaugh

Barrett

Dissent

Sotomayor

Kagan

Jackson

““Section 2255(e) does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to circumvent” AEDPA’s restrictions on second or successive motions by filing a habeas petition.”

Federal prisoners who have already used their first post-conviction challenge cannot bring this type of claim through a separate habeas petition. For example, a prisoner cannot use that route solely because a later court decision reads the criminal statute differently.

Lower courts must apply this rule when federal prisoners seek to use habeas petitions for claims based on later readings of criminal statutes. Affected prisoners must use the post-conviction routes that AEDPA permits.

The Court said the saving clause does not let federal prisoners evade limits on repeat post-conviction motions through a separate habeas petition.

Federal prisoners who already completed an initial post-conviction challenge and later rely on a new interpretation of their criminal statute are affected.

They must reject attempts to use the saving clause and separate habeas petitions to bypass AEDPA's restrictions on repeat motions.