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The U.S. Supreme Court has left certain defendants without legal recourse to assert their actual innocence due to a change in statutory interpretation. The decision, handed down on June 22, revolves around the case of Marcus DeAngelo Jones and has raised concerns among civil liberties organizations and advocates for fair and just prosecution.
Jones was convicted in 2000 for unlawful firearm possession by a felon, resulting in a 27-year sentence. However, in 2019, the Supreme Court’s decision in Rehaif v. United States established that a defendant cannot be convicted of such a crime unless they were aware that they fell into the category of persons prohibited from possessing firearms.
During Jones’ trial, no evidence was presented to demonstrate his awareness of his status as a felon. According to a press release by Fair and Just Prosecution, he testified that he believed his criminal record had been expunged. Seeking to assert his innocence, Jones filed a motion to vacate his conviction under Section 2255 of Title 28 of the U.S. Code.
However, the Supreme Court’s ruling, delivered in a 6-3 decision with Justice Clarence Thomas writing the majority opinion, rejected Jones’ claim. The court held that Jones was ineligible to file a second petition to vacate his conviction, even in light of the later Supreme Court decision rendering his conduct legal. Justices Sonia Sotomayor, Elena Kagan, and Ketanji Brown Jackson dissented from the majority opinion.
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The decision has drawn criticism from various quarters, with SCOTUSblog providing coverage, the American Civil Liberties Union (ACLU), and Fair and Just Prosecution issuing press releases denouncing the ruling. The ACLU stated in its press release that the denial of a day in court for individuals imprisoned for conduct that is not a crime represents a significant blow to fairness and justice across the nation.
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Jones’ case highlights the broader issue of limited options for prisoners seeking to challenge their convictions based on statutory innocence claims. The Supreme Court’s ruling reaffirms the Antiterrorism and Effective Death Penalty Act’s general prohibition on second or successive Section 2255 motions. Under the act, such motions are only permitted if they rely on “newly discovered evidence” or “a new rule of constitutional law.”
In writing the majority opinion, Justice Thomas explained that Jones’ new Section 2255 motion did not qualify because it was based on a more favorable interpretation of statutory law rather than newly discovered evidence or a new constitutional rule. Furthermore, Thomas argued that Jones could not invoke Section 2255’s savings clause, which allows prisoners to seek habeas relief if a Section 2255 motion is “inadequate or ineffective to test the legality of his detention.” According to Thomas, the savings clause does not permit an “end-run around” the Antiterrorism and Effective Death Penalty Act.
Justice Ketanji Brown Jackson, in her dissent, characterized the majority’s decision as preventing incarcerated individuals who have already filed one post-conviction petition from filing another to assert a previously unavailable claim of statutory innocence. Jackson expressed concerns about the serious constitutional implications of forever closing the courtroom doors to potentially innocent individuals.
Another dissenting opinion, authored by Justices Sotomayor and Kagan, raised troubling concerns about the consequences of the majority’s decision. They emphasized the importance of providing avenues for asserting statutory innocence claims, particularly when new developments in legal interpretation demonstrate that certain conduct was not illegal.
This Supreme Court ruling, while specific to Jones’ case, has wider implications for defendants seeking to challenge their convictions based on statutory innocence claims. It highlights the limitations imposed by the Antiterrorism and Effective Death Penalty Act and raises questions about the fairness and justice of the existing legal framework. Advocates for criminal justice reform and organizations focused on civil liberties continue to voice their concerns about the potential consequences of such limitations on defendants’ ability to assert their innocence in the face of evolving legal interpretations.
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