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

QUESTION PRESENTED : 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. ; : ; iil