Case Citator › William Andrew Wright v. Stephen Spaulding

William Andrew Wright v. Stephen Spaulding

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
Sixth Circuit
Citation
939 F.3d 695
Decided
Confirmed treatments
1
Flagged citations read
32 of 32
Citing cases (total)
32
Treatment dates
2023
Abrogated
A reviewed court treats this case as abrogated by later authority. All 32 flagged citations have been read. Jones v. Hendrix ended the route through 28 U.S.C. § 2241 that Wright v. Spaulding had treated as potentially available after an intervening change in statutory interpretation when a prisoner lacked an earlier opportunity to raise the claim.
More on how this was screened

The abrogation is limited to that saving clause doctrine; later courts still cite Wright's separate discussion of binding precedent. A later Western District of Tennessee order in Martin v. Warden FCI Memphis likewise recognized that Jones rejected the Sixth Circuit's earlier route for such claims. The confirmed treatment is listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

32 later cases cite William Andrew Wright v. Stephen Spaulding; 32 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

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Treatments

Abrogated

  • The Supreme Court foreclosed the saving clause route for a second collateral attack based on an intervening interpretation of a criminal statute, displacing Wright's test for access to that route.

    Jones v. Hendrix · Supreme Court of the United States · filed

    We now hold that the saving clause does not authorize such an end-run around AEDPA. In § 2255(h), Congress enumerated two—and only two—conditions in which a second or successive § 2255 motion may proceed.
    Read the full opinion on CourtListener →

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