John Worman v. Frederick Entzel

Summary

The Seventh Circuit held that a federal prisoner cannot use 28 U.S.C. § 2241 to challenge his sentence under the savings clause of § 2255(e) based on *Dean v. United States*, 137 S. Ct. 1170 (2017), because *Dean* announced a new procedural rule that does not apply retroactively on collateral review under *Teague v. Lane*. The court applied a three-part test for the savings clause and concluded that *Dean* is not a substantive rule or a watershed procedural rule, so it cannot satisfy the "miscarriage of justice" requirement. The case underscores the stringent limits on second or successive habeas motions and the narrow availability of § 2241 relief for sentencing errors.

Holdings

1. Dean announced a new procedural rule that does not apply retroactively under Teague v. Lane because it is not a substantive rule and does not qualify as a watershed rule of criminal procedure.

Questions Presented

1. Whether Dean v. United States applies retroactively to cases on collateral review such that Worman can use 28 U.S.C. § 2241 to challenge his sentence under the savings clause of § 2255(e).

Disposition

affirmed