Matthews v. Rios

Defendant could not properly proceed on section 2241 habeas petition that challenged his 180-month sentence that was based in part on finding that defendant qualified as armed career offender based in part on prior Illinois conviction for unlawful possession of weapon by felon that Dist. Ct. originally determined was “violent felony” for purposes of applying Armed Career Offender Act. Defendant’s argument was previously rejected by Ct. of Appeals on direct appeal, and Dist. Ct. denied similar argument in prior section 2255 petition. Section 2255(e) restricts prisoner from submitting instant habeas petition where prisoner’s prior habeas petition had been denied, and where prior habeas petition was not inadequate means to test legality of his detention.