William Chaffin, Jr. v. Warden of FCI-Allenwood Medium

• Court: Court of Appeals for the Third Circuit
• Decided: May 2, 2024
• Docket: 23-1345
• Status: Unpublished

Opinion

BLD-109 NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________

No. 23-1345 ___________

WILLIAM J. CHAFFIN, JR., Appellant

v.

WARDEN OF ALLENWOOD FCI MEDIUM ____________________________________

On Appeal from the United States District Court for the Middle District of Pennsylvania (D.C. Civil Action No. 4-22-cv-01242) District Judge: Honorable Matthew W. Brann ____________________________________

Submitted for Possible Dismissal Due to a Jurisdictional Defect and on Appellee’s Motion for Summary Action Pursuant to Third Circuit L.A.R. 27.4 and I.O.P. 10.6 April 18, 2024

Before: BIBAS, MATEY, and CHUNG, Circuit Judges

(Opinion: May 2, 2024) _________

OPINION * _________ PER CURIAM

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. William J. Chaffin, Jr., a federal prisoner who is proceeding pro se, appeals from

an order dismissing his petition for a writ of habeas corpus under 28 U.S.C. § 2241. The

Government has moved for summary affirmance. For the following reasons, we grant the

Government’s motion and will summarily affirm the District Court’s judgment.

Chaffin pleaded guilty to charges involving cocaine distribution in 2017. He was

deemed to be a career offender under the United States Sentencing Guidelines, and was

sentenced to 180 months of imprisonment. He did not challenge the judgment on appeal

or in a motion under 28 U.S.C. § 2255.

In 2022, Chaffin, who was confined at FCI Allenwood, filed a petition pursuant to

§ 2241 in the United States District Court for the Middle District of Pennsylvania. He

argued that his “prior convictions do not qualify him as a career offender” under Mathis

v. United States, 579 U.S. 500 (2016), and Descamps v. United States, 570 U.S. 254

(2013). (ECF 1, at 6 of 10.) The District Court dismissed the § 2241 petition for lack of

jurisdiction. Chaffin appealed. 1

We have jurisdiction pursuant to 28 U.S.C. § 1291. In reviewing the District

Court’s dismissal of Chaffin’s § 2241 petition, we exercise plenary review over its legal

conclusions and review any factual findings for clear error. See Cradle v. United States

ex rel. Miner, 290 F.3d 536, 538 (3d Cir. 2002) (per curiam). We may summarily affirm

1 Chaffin did not file his notice of appeal within 60 days of the entry of the District Court’s order, as he was required to do under Federal Rule of Appellate Procedure 4(a)(1)(B). But this appeal is nevertheless timely because the District Court subsequently granted Chaffin’s request to reopen the time to appeal pursuant to Federal Rule of Appellate Procedure 4(a)(6).

2 a District Court’s decision “on any basis supported by the record” if the appeal fails to

present a substantial question. See Murray v. Bledsoe, 650 F.3d 246, 247 (3d Cir. 2011)

(per curiam); 3d Cir. L.A.R. 27.4; 3d Cir. I.O.P. 10.6.

“Motions pursuant to 28 U.S.C. § 2255 are the presumptive means by which

federal prisoners can challenge their convictions or sentences[.]” Okereke v. United

States, 307 F.3d 117, 120 (3d Cir. 2002). Chaffin instead sought to proceed under

§ 2241. But, under 28 U.S.C. § 2255(e) (also known as the saving clause), the District

Court could not entertain his § 2241 petition unless “it . . . appear[ed] that the remedy by

[§ 2255] motion [was] inadequate or ineffective to test the legality of [his] detention.”

While Chaffin’s appeal was pending, the Supreme Court clarified that “the saving clause

preserves recourse to § 2241 in cases where unusual circumstances make it impossible or

impracticable to seek relief in the sentencing court, as well as for challenges to detention

other than collateral attacks on a sentence.” Jones v. Hendrix, 599 U.S. 465, 478 (2023).

Those unusual circumstances are absent from Chaffin’s collateral attack on his sentence.

Id. at 504 (Jackson, J., dissenting) (providing examples of such circumstances).

Therefore, Chaffin cannot bring his claims under § 2241. And this is true even if he faces

procedural or other obstacles to bringing his claim in a first § 2255 motion. See Cradle,

290 F.3d at 539; cf. Voneida v. Johnson, 88 F.4th 233, 235 (3d Cir. 2023) (explaining

that Jones “established that the limitations on second or successive motions set forth in 28

U.S.C. § 2255(h) do not make § 2255 ‘inadequate or ineffective’ such that a prisoner

must pursue a remedy under § 2241”).

3 For these reasons, the District Court properly dismissed Chaffin’s § 2241 petition

for lack of jurisdiction. Accordingly, we grant the Government’s motion and will

summarily affirm the District Court’s judgment.