Litigation Reform Act of 1995 (PLRA), 42 U.S.C. § 1997e(a). It did not hold, however, that an inmate’s failure to exhaust administrative remedies deprived courts of subject matter jurisdiction over a 28 U.S.C. § 2241 petition or any other type of claim. 2 . Skinner and "Winck mention Gonzalez’s holding only in dicta. Skinner, 355 F.3d at 1295; "Winck, 327 F.3d at 1300 n. 1. Lucas and Mitchell predate Gonzalez and do not address § 2241 petitions at all. Lucas, 898 F.2d at 1555; Mitchell, 845 F.2d at 952-53. 3 . Beginning in 2005, 13 years after Gonzalez was decided, Congress enacted a series of amendments to § 2241 aimed at limiting the jurisdiction of courts to hear § 2241 petitions brought by aliens detained as enemy combatants. See Pub.L. No. 109-148, § 1005(e)(1), 119 th Cir.2009) (<HOLDING>); United States v. Archer, 531 F.3d 1347, 1352
holding that one of our prior panel precedents involving the armed career criminal act was undermined to the point of abrogation by shepard v united states 544 us 13 125 sct 1254 161 led2d 205 2005 even though shepard dealt with a different provision of that act holding that one of our prior panel precedents about when criminal filing deadlines are jurisdictional was abrogated by bowles v russell 551 us 205 127 sct 2360 168 led2d 96 2007 even though bowles dealt with civil filing deadlines holding that appellate deadlines are stayed during pendency of automatic stay imposed by insurance code holding that filing of an administrative complaint did not meet the requirement that the employee seek counseling prior to filing holding that where a state court applies the harmless beyond a reasonable doubt standard a federal court may not award habeas relief under  2254 unless the harmlessness determination itself was unreasonable emphasis in original quoting fry v pliler 551 us 112 119 127 sct 2321 168 led2d 16 2007