Means v. State of Alabama

Clay Means, a federal prisoner proceeding pro se, appeals from the district court’s denial of his habeas corpus petition, brought under 28 U.S.C. § 2254, attacking a state conviction whose sentence had run that was used to enhance his current federal sentence.

On appeal, Means argues that the district court correctly construed his habeas petition as arising under § 2254. The district court found that Means’s claim was procedurally barred. Means maintains that the claim was not procedurally barred, or, in the alternative, that he met the burden of showing actual innocence to overcome that bar.

A…