In Garland v. Roy, No. 09-40735, which involved petitioner’s appeal from the dismissal of his habeas corpus petition brought pursuant to 28 U.S.C. section 2241, the court reversed on the ground that, in light of the Supreme Court’s decision in Santos, petitioner brought a claim that satisfied each of the Reyes-Requena factors, and thus his petition fell within section 2255’s savings clause, allowing him to bring a habeas petition under section 2241.

Related Resources

  • Full Text of Garland v. Roy, No. 09-40735
  • Full Text of US v. Zapata-Lara, No. 09-40627

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