Willis v. Warden, USP Canaan

Summary

The United States District Court for the Middle District of Pennsylvania dismisses Eugene Willis’s 28 U.S.C. § 2241 petition for lack of jurisdiction. Willis sought to vacate his § 924(c) conviction based on Supreme Court decisions including Taylor, Davis, and Rosemond. The court holds that his challenge must be brought under 28 U.S.C. § 2255 in the sentencing court and that § 2241 is unavailable merely because procedural restrictions may bar relief under § 2255.

Holdings

1. A federal prisoner may not use § 2241 to challenge the validity of a conviction when it is not essentially impossible or impracticable to seek relief in the sentencing court under § 2255, even if the prisoner may be barred by § 2255's limitations on successive motions or other procedural restrictions.
2. The court lacked jurisdiction over Willis's § 2241 petition because the petition challenged the validity of his conviction and it was not essentially impossible for him to seek relief under § 2255 in the sentencing court.

Questions Presented

1. Whether a federal prisoner may use a 28 U.S.C. § 2241 petition to challenge the validity of a § 924(c) conviction based on intervening legal decisions when relief remains available, though potentially subject to procedural restrictions, under 28 U.S.C. § 2255.
2. Whether the Middle District of Pennsylvania had jurisdiction over Willis's § 2241 petition.

Disposition

dismissed