Whether the savings clause of 28 U.S.C. § 2255(e) is available where the circuit having § 2255 venue imposes a categorical structural bar on federal inmates seeking redress for a meritorious Sixth Amendment violation

QUESTIONS PRESENTED: 1. The savings clause of 28 U.S.C. § 2255(e) provides a residual habeas forum for federal inmates in cases in which a § 2255 motion is “inadequate or ineffective to test the legality of . . . [their] detention.” Did the court of appeals below err in holding that this “savings clause” is unavailable where the circuit having § 2255 venue imposes a categorical structural bar on federal inmates seeking redress for a meritorious Sixth Amendment violation? 2. Whether a defendant advancing a Brady claim due to the prosecution’s long concealment of evidence deemed material must also demonstrate that he or she could not have uncovered some part of the suppressed evidence through the exercise of due diligence? i