What is the test for a motion to review a federal conviction under section 2255 of the Civil Rights Act?

It is apparent from Springfield's pleadings that he did not intend to file a civil rights claim. He erroneously denominated his first petition as one seeking habeas corpus relief under 28 U.S.C. Sec. 2241 and 28 U.S.C. Sec. 1651. The district court compounded his error by returning to him a "Form to Be Used by Prisoners in Filing a Complaint Under the Civil Rights Act, 42 U.S.C. 1983," which he completed and filed. In both pleadings he was attacking the validity of, and seeking relief from, his federal conviction. In order to do this properly, he should have filed a motion under 18 U.S.C. Sec. 2255 in the court which sentenced him. This section provides him an adequate and effective remedy. United States v. Hayman, 342 U.S. 205, 223 (1952).

Because Springfield is acting as his own counsel in this matter, we do not impose on him the same high standards we might place upon an attorney. Price v. Johnston, 334 U.S. 266, 292 (1948). We therefore construe his pleadings liberally and find them sufficient to constitute a section 2255 motion without need for amendment. We construe the district court's dismissal as a denial of this motion and review de novo.