Phillips v. Johnson, Director, Virginia Department of Corrections

How later courts describe this case

• holding that § 2255 had not been inadequate or ineffective to test the legality of the petitioner’s conviction where the petitioner “[had] not been denied an unobstructed procedural opportunity to present [his claim]”
• “savings clause” exception to section 2255 exclusivity unavailable where the petitioner once could have brought the desired challenge, but failed to do so