Fields v. Gilley

Plaintiff appealed after the district court dismissed his petition for a writ of habeas corpus that he filed under 28 U.S.C. § 2241. Plaintiff had previously sought relief under 28 U.S.C. § 2255. The Seventh Circuit affirmed, holding that the district court properly held that plaintiff could not pursue his allegations of judicial bias under § 2255 because his claims did not fall within the two categories of claims that can be brought in a successive § 2255 petition and that the inability to assert a judicial bias claim in a successive § 2255 motion did not make § 2241 available to the plaintiff. (JACKSON-AKIWUMI and PRYOR, concurring)