18 U.S.C. § 2255 does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to circumvent AEDPA's restrictions on second or successive § 2255 motions by filing a habeas petition under 28 U.S.C. § 2241

 In Jones v. Hendrix, Warden, No. 21-857 (June 22, 2023), the Supreme Court ruled that 18 U.S.C. § 2255 does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to circumvent AEDPA's restrictions on second or successive § 2255 motions by filing a habeas petition under 28 U.S.C. § 2241. Petitioners who are restricted from filing a § 2255 petition can no longer seek relief under 28 U.S.C. § 2241 in lieu of § 2255, even if they are actually innocent or serving an illegal sentence. This is because the Supreme Court found that § 2255(e) - the savings clause - only covers individuals who literally cannot file a § 2255 motion. This holding abrogates the more favorable Third Circuit holding in In re Dorsainvil, 119 F. 3d 245, 251 (3d. Cir. 1997).