Whether the Courts of Appeals have incorrectly interpreted the 'savings clause', found in 28 USC 2255(e), to require that a defendant be sentenced under mandatory guidelines in order to proceed under 28 USC 2241 by way of 2255(e) when a sentence was based on an incorrect guideline range and subsequent caselaw reveals the error.

Whether the Courts of Appeals have incorrectly interpreted the 'savings clause' found in 28 USC 2255(e)