Bryant, Jr. v. Warden, FCC Coleman - Medium, No. 12-11212 (11th Cir. 2013)
Annotate this CasePetitioner pled guilty to one count of knowingly possessing firearms and ammunition while being a convicted felon in violation of 18 U.S.C. 933(g)(1) and 924(e). On appeal, petitioner challenged the district court's dismissal of his 28 U.S.C. 2241 habeas petition, brought pursuant to the "savings clause" in 28 U.S.C. 2255(e). The court concluded that defendant has proven that his prior section 2255 motion was "inadequate or ineffective to test the legality of his detention" and that his 2241 petition could not proceed under section 2255(e) because: (1) from the time of his initial sentencing in 2002 throughout his first section 2255 proceeding in 2005, the court's binding precedent in United States v. Hall held that a concealed-firearm offense under Fla. Stat. 790.01 was a "violent felony" under section 924(a); (2) subsequent to petitioner's first 2255 proceeding, the Supreme Court's decision in Begay v. United States set forth a new standard to evaluate which crimes constituted violent felonies under section 924(e), and Begay, as interpreted by United States v. Archer overturned the court's precedent in Hall; (3) Begay's new rule is substantive and applies retroactively to petitioner's section 924(e) claim on collateral review; (4) as a result of pure section 924(a)-Begay error and retroactive application of Begay, petitioner's 235-month sentence exceeds the 10-year statutory minimum authorized by Congress in section 924(a); and (5) the savings clause in section 2255(e) reaches his claim of illegal detention above the statutory maximum penalty. Accordingly, the court vacated and remanded with instructions.
The court issued a subsequent related opinion or order on May 15, 2014.
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