United States of America v. James T. Williams, also known as MAX, also known as MATH

BLD-081 NOT PRECEDENTIAL
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
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No. 22-3196
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UNITED STATES OF AMERICA,
v.
JAMES T. WILLIAMS, also known as MAX, also known as MATH, Appellant
____________________________________
On Appeal from the United States District Court
for the Eastern District of Pennsylvania
(D.C. Civil Action No. 2-95-cr-00407-002)
District Judge: Honorable Joel H. Slomsky
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Submitted for Possible Summary Action
Pursuant to Third Circuit LAR 27.4 and I.O.P. 10.6
January 26, 2023
Before: AMBRO, KRAUSE, and PORTER, Circuit Judges
(Opinion filed: March 22, 2023)
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OPINION*
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PER CURIAM
James Williams appeals from the District Court’s order denying his petition for a
writ of habeas corpus under 28 U.S.C. § 2241. He has filed a motion to summarily
* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not
constitute binding precedent.

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reverse the District Court’s judgment. For the reasons that follow, we will deny his
motion and will summarily affirm the judgment below.
I.
In 1996, an Eastern District of Pennsylvania jury found Williams guilty of crimes
related to three armed bank robberies. He was sentenced to 687 months’ imprisonment.
Williams did not obtain relief on direct appeal. In March 1999, Williams timely filed a
pro se 28 U.S.C. § 2255 motion, which appointed counsel later amended. In April 2000,
the District Court conducted a hearing on the § 2255 motion, and partially granted
Williams’s motion to proceed pro se by allowing him to submit supplemental claims for
counsel to file by August 1, 2000. Over one year later, on August 7, 2001, Williams
sought to add supplemental claims to his motion, but the District Court denied his request
because the deadline for raising such claims had long passed. The District Court denied
Williams’s § 2255 motion on the merits and declined to issue a COA. United States v.
Williams, 166 F. Supp. 2d 286 (E.D. Pa. 2001). Williams appealed and this Court denied
his request for a COA. United States v. Williams, C.A. 01-4125 (order entered Sept. 24,
2002). For years, Williams has unsuccessfully challenged the District Court’s failure to
adjudicate those supplemental claims and its denial of his right to represent himself
during his initial collateral proceeding by filing § 2241 petitions and § 2255 motions in
the District Court. In this Court, he has twice sought leave under 28 U.S.C. § 2244(b)(3)
and § 2255(h) to file a successive § 2255 motion; those requests were denied because
Williams had not satisfied the standard for filing a successive motion.

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In June 2022, Williams filed the at-issue § 2241 petition, renewing his arguments
about the denial of his right to self-representation and the District Court’s failure to
adjudicate the supplemental claims in his initial § 2255 proceeding. The District Court
denied the § 2241 petition, because Williams had not demonstrated that a § 2255 motion
would be an inadequate or ineffective means to challenge the legality of his detention.
See ECF No. 507. Williams timely appealed. He now moves to summarily reverse the
District Court’s denial order.
II.1
A motion filed under § 2255 in the sentencing court is the presumptive means for
a federal prisoner to challenge the validity of a conviction or sentence. See Okereke v.
United States, 307 F.3d 117, 120 (3d Cir. 2002). A habeas corpus petition filed pursuant
to § 2241 accordingly “shall not be entertained” unless a § 2255 motion would be
“inadequate or ineffective to test the legality of [petitioner’s] detention.” 28 U.S.C.
§ 2255(e). “A § 2255 motion is inadequate or ineffective only where the petitioner
demonstrates that some limitation of scope or procedure would prevent a § 2255
proceeding from affording him a full hearing and adjudication of his wrongful detention
claim.” Cradle, 290 F.3d at 538. This “safety-valve” exception is narrow and applies
1 We have jurisdiction under 28 U.S.C. § 1291. We exercise plenary review over the
District Court’s legal conclusions and review the District Court’s factual findings for
clear error. Cradle v. United States ex rel. Miner, 290 F.3d 536, 538 (3d Cir. 2002) (per
curiam). We may summarily affirm a judgment of the District Court on any basis
supported by the record if the appeal does not raise a substantial question. See I.O.P.
10.6; see also Murray v. Bledsoe, 650 F.3d 246, 247 (3d Cir. 2011).

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only in rare circumstances, such as when “an intervening change in statutory
interpretation runs the risk that an individual was convicted of conduct that is not a crime,
and that change in the law applies retroactively in cases on collateral review.” See Bruce
v. Warden Lewisburg USP, 868 F.3d 170, 179 (3d Cir. 2017).
We agree with the District Court that Williams may not resort to § 2241 as a
remedy because he did not satisfy § 2255(e)’s safety-valve provision. Williams argues
that our decision in United States v. Taylor, 21 F.4 th 94 (3d Cir. 2021), requires vacating
the judgment below, see C.A. No. 4 at p. 2, but his invocation of Taylor is misplaced.
Taylor was a direct appeal opinion that involved a district court’s failure to adequately
admonish a defendant during pre-trial proceedings about the attendant risks and
consequences of waiving his right to counsel and representing himself. 21 F.4 th at 101-
02. That case has no bearing on whether the conduct underlying Williams’s armed
robbery convictions is non-criminal.
As for Williams’s supplemental claims (most of which appear to be prosecutorial
misconduct and Brady2 claims), see ECF No. 499 at pp. 7, 12, the District Court correctly
explained that § 2241 was not the appropriate vehicle to raise such claims. The proper
avenue for pursuing relief for those claims was via a § 2255 motion. Because Williams
had already filed a § 2255 motion that was adjudicated on the merits, he can only
advance a new claim for relief in a successive § 2255 motion. See 28 U.S.C. § 2255(h).
To file a successive motion, Williams needed, but did not have, authorization from this
2 See Brady v. Maryland, 373 U.S. 83 (1963).

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Court. See id.; see also Robinson v. Johnson, 313 F.3d 128, 139 (3d Cir. 2002). To
obtain such authorization, Williams needs to point to a new rule of constitutional law that
is retroactively applicable or newly-discovered facts establishing his innocence,
see § 2255(h), but he has done neither. The fact that Williams cannot satisfy the stringent
gatekeeping requirements for filing a second or successive § 2255 motion does not render
§ 2255 an inadequate or ineffective remedy to pursue relief. See Cradle, 290 F.3d at 539.
III.
Williams has not shown an intervening change in law or other extraordinary
circumstances that would render § 2255 inadequate or ineffective to challenge his
conviction and sentence. The District Court therefore properly denied his § 2241
petition. Because this appeal does not present a substantial question, we will summarily
affirm the judgment of the District Court, and we deny Williams’s motion to summarily
reverse. See 3d Cir. L.A.R. 27.4; IO.P. 10.6.

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