United States Court of Appeals 

For the Seventh Circuit 

Chicago, Illinois 60604 

Submitted November 17, 2020 

Decided November 18, 2020 

Before 

DIANE S. SYKES, Chief Judge 

DAVID F. HAMILTON, Circuit Judge 

AMY J. ST. EVE, Circuit Judge

No. 20-3216 

ORLANDO CORDIA HALL, 

Petitioner-Appellant, 

v. 

T. J. WATSON, Warden, 

 Respondent-Appellee.

 Appeal from the 

United States District Court for the 

Southern District of Indiana, 

Terre Haute Division. 

No. 2:17-cv-00176-JPH-DLP 

James P. Hanlon, 

Judge. 

O R D E R 

In September 1994, Orlando Hall and three coconspirators armed themselves 

with handguns and a baseball bat and forcibly kidnapped 16-year-old Lisa Rene from 

her brother’s apartment in Texas and drove her to Arkansas. United States v. Hall, 

152 F.3d 381, 389 (5th Cir. 1998). Hall was a drug dealer, and he suspected Lisa’s brother 

of reneging on a drug transaction. Id. For two days Hall and the others repeatedly raped 

Lisa. Id. Then, because she knew too much, they killed her by bashing her head with a 

shovel, gagging her, dousing her with gasoline, and burying her alive. Id. at 390. 
No. 20-3216 Page 2 

A federal jury in the Northern District of Texas found Hall guilty on a capital 

count of kidnapping resulting in death in violation of 18 U.S.C. § 1201(a)(1) and 

recommended a death sentence pursuant to the Federal Death Penalty Act of 1994, 

18 U.S.C. §§ 3591–3598. Hall, 152 F.3d at 390. Hall was also convicted of three other 

crimes: conspiracy to commit kidnapping in violation of 18 U.S.C. § 1201(c); traveling in 

interstate commerce with intent to commit a narcotics offense, id. § 1952; and using or 

carrying a firearm during a crime of violence in violation of 18 U.S.C. § 924(c). Hall, 

152 F.3d at 390. The § 1201(a)(1) count, kidnapping causing death, was the predicate 

crime of violence for the § 924(c) count. The judge imposed a death sentence on the 

capital kidnapping count as recommended by the jury. Id. For the three noncapital 

counts, the judge structured the sentence as follows: a life sentence on the conspiracy 

count, a 60-month concurrent sentence on the narcotics count, and a 60-month 

consecutive sentence on the § 924(c) count. Id.

The Fifth Circuit affirmed on direct appeal, id. at 427, and Hall twice 

unsuccessfully pursued collateral relief under 28 U.S.C. § 2255, In re Hall, No. 19-10345, 

2020 WL 6375718, at *2 (5th Cir. Oct. 30, 2020). This case involves his third attempt at 

collateral relief. Hall asked the Fifth Circuit to authorize a successive § 2255 motion to 

permit him to challenge his § 924(c) conviction in light of United States v. Davis, 

139 S. Ct. 2319, 2336 (2019), which invalidated § 924(c)(3)(B)—the so-called “residual 

clause” in the definition of “crime of violence”—as unconstitutionally vague. He argued 

that the invalidity of the § 924(c) count entitled him to full resentencing on all counts, 

including the § 1201(a)(1) conviction for kidnapping resulting in death for which he 

received the death sentence. In a comprehensive opinion, the Fifth Circuit rejected the 

claim on the merits and on that basis denied authorization. Specifically, the court held 

that Davis has no effect on Hall’s § 924(c) conviction because the predicate offense—the 

capital kidnapping count—is a crime of violence under § 924(c)(3)(A), the so-called 

“elements clause” of the crime-of-violence definition. In re Hall, 2020 WL 6375718, at *5. 

Hall next turned to the Southern District of Indiana, where he is confined, 

seeking relief under 28 U.S.C. § 2241, the general habeas statute, and raising the same 

Davis challenge to his § 924(c) conviction. Under § 2255(e), a § 2241 habeas petition 

“shall not be entertained” unless the remedy by motion under § 2255 is “inadequate or 

ineffective to test the legality of” the prisoner’s detention. We’ve explained that this 

“Savings Clause” opens a “‘narrow pathway’” to § 2241, but “to proceed down that 

path[,] there must be something ‘structurally inadequate or ineffective about [§] 2255 as 

a vehicle’ for the arguments raised in the § 2241 petition.” Lee v. Watson, 964 F.3d 663, 

666 (7th Cir. 2020) (quoting Purkey v. United States, 964 F.3d 603, 611, 617 (7th Cir. 2020)). 
No. 20-3216 Page 3 

The district court dismissed the § 2241 petition, ruling that § 2255 is not inadequate or 

ineffective as a vehicle for Hall’s Davis argument. The judge also denied his request for 

a stay of execution. Hall appealed and renewed his motion for a stay of execution. 

We summarily affirm and deny the stay motion. This appeal is meritless for two 

independent reasons. First, the death penalty was imposed on the conviction for 

kidnapping resulting in death; that sentence stands on its own factual and legal 

foundation and is unaffected by the validity or invalidity of Hall’s § 924(c) conviction. 

Second, Hall’s Davis challenge to his § 924(c) conviction is not cognizable under 

§ 2241. To repeat: The Savings Clause is unavailable absent a structural defect in § 2255. 

There is nothing structurally inadequate or ineffective about § 2255 as a vehicle for 

Hall’s Davis challenge. Indeed, the Fifth Circuit thoroughly addressed the claim on the 

merits and rejected it. In re Hall, 2020 WL 6375718, at *3–5. To access § 2241 via the 

narrow gateway of the Savings Clause requires “‘a compelling showing’ that it was 

‘impossible’ to use § 2255 to cure the defect identified in the § 2241 petition; ‘[i]t is not 

enough that proper use of the statute results in a denial of relief.’” Lee, 964 F.3d at 666 

(quoting Purkey, 964 F.3d at 615). Put slightly differently, “the words ‘inadequate or 

ineffective,’ taken in context, must mean something more than unsuccessful.” Purkey, 

964 F.3d at 615. Hall’s claim was simply unsuccessful; he challenged his § 924(c) 

conviction in light of Davis and lost. There’s nothing structurally inadequate or 

ineffective about § 2255 as a vehicle for this claim. 

The district court’s judgment is summarily AFFIRMED; the stay motion is 

DENIED.