Can a federal prisoner challenge the manner, location or conditions of a sentence's execution by filing a petition pursuant to Section 2241 of the Criminal Code?

prisoner must challenge the manner, location, or conditions of a sentence's execution by filing a petition pursuant to 2241 in the "custodial court," that is, the court of the district in which he is incarcerated. Id. at 864. If the prisoner challenges the legality of his conviction or sentence, however, he must bring a 2255 motion in the district of conviction. Stephens v. Herrera, 464 F.3d 895, 897 (9^th Cir. 2006). The prisoner cannot avoid the restrictions of a 2255 motion by attempting to challenge his conviction or sentence by means of a 2241 petition in the custodial court. Id. If this general rule applies, a petitioner cannot seek modification of his sentence by filing a 2241 petition.

An exception to the 2241 limitations, commonly referred to as the "escape hatch" or the "savings clause," "permits a federal prisoner to file a habeas corpus petition pursuant to 2241 to contest the legality of a sentence where his remedy under 2255 is inadequate or ineffective to test the legality of his detention." Id. (citations and internal quotations omitted). "[A] prisoner may file a 2241 petition under the escape hatch when the prisoner (1) makes a claim of actual innocence, and (2) has not had an unobstructed procedural shot at presenting that claim." Marrero v. Ives, 682 F.3d 1190, 1192 (9^th Cir. 2012) (internal quotations omitted). "If the prisoner's claims qualify for the escape hatch of 2255, the prisoner may challenge the legality of a sentence through a 2241 petition in the custodial court." Harrison v. Ollison, 519 F.3d 952, 956 (9^th Cir. 2008).