In Holland v. Warden Canaan USP, the Third Circuit heard a rare appeal from the denial of post-conviction relief based on a petition filed under 28 U.S.C. § 2241 instead of § 2255. Here, the petitioner was convicted of violating 18 U.S.C. § 924(c) when he traded drugs for a gun. After the date of the conviction, in Watson v. United States, the Supreme Court held as a matter of statutory interpretation that trading guns for drugs is not a violation of § 924(c). The Third Circuit ruled that the courts had jurisdiction because while § 2255 petitions can be based on a new rule of constitutional law, § 2241 petitions are also available for a new rule of statutory law. The Court then determined that it could entertain this petition — the petitioner’s fourth § 2241 filing — because the statutory limit on petitions is discretionary. Accordingly, the Third Circuit remanded for the District Court to conduct a hearing on the merits.