Case Citator › In re Jones

In re Jones

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

Overruled
Court
Fourth Circuit
Citation
226 F.3d 328
Decided
Confirmed treatments
1
Flagged citations read
47 of 47
Citing cases (total)
47
Treatment dates
2023
Overruled
A reviewed court has overruled this case. In re Jones has been overruled on its rule permitting some federal prisoners to use § 2241 after a later statutory interpretation makes their conduct noncriminal. The Supreme Court rejected that route in Jones v. Hendrix, and the Fourth Circuit later said the In re Jones savings clause test is no longer good law.
More on how this was screened

In re Jones's separate conclusion that AEDPA's restrictions on successive § 2255 motions applied to the prisoner was not displaced. All 47 flagged citations have been read; 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.

47 later cases cite In re Jones; 47 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.

Relying on In re Jones?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled

  • The Supreme Court rejected In re Jones's rule allowing a § 2241 petition when an intervening statutory interpretation made conduct noncriminal but § 2255 barred a successive motion.

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

    Several Courts of Appeals found a workaround for those prisoners in the saving clause. With minor differences in reasoning and wording, they held that §2255 was “inade- quate and ineffective” under the saving clause—and that §2241 was therefore available—when AEDPA’s second-or- successive restrictions barred a prisoner from seeking relief based on a newly adopted narrowing interpretation of a criminal statute that circuit precedent had foreclosed at the time of the prisoner’s trial, appeal, and first §2255 motion. ... In re Jones, 226 F. 3d 328, 333–334 (CA4 2000); ... We now hold that the saving clause does not authorize such an end-run around AEDPA.
    Read the full opinion on CourtListener →

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