With no explanation, chose the best option from "A", "B", "C" or "D". for relief under § 3582(c). Nor is Brown entitled to pursue his claims through § 2241. A prisoner may proceed under § 2241 if § 2255 would be “inadequate of ineffective.” 28 U.S.C. § 2255(e); Cradle v. United States ex rel. Miner, 290 F.3d 536, 538 (3d Cir.2002) (per curiam). We have held that § 2255’s “safety valve” applies only in rare circumstances, such as when an intervening change in the statute under which the petitioner was convicted renders the petitioner’s conduct non-criminal. See In re Dorsainvil, 119 F.3d 245, 251 (3d Cir. 1997). Brown has not satisfied that standard here, as he makes no allegation that he is actually innocent of the crime for which he was convicted, but instead asserts only that he is “innocent” of being a career offender. See Okereke, 307 F.3d at 120-21 (<HOLDING>). Brown must obtain a certificate of

A: holding that dorsainvil did not permit petitioner to challenge sentence via  2241 based on intervening change in sentencing law
B: holding that a  2241 petitioners claim was not cognizable under  2241 and therefore the district court lacked jurisdiction
C: holding that a change in the law of sentencing does not constitute a new factor
D: holding that prisoners challenge to his sentencing enhancement under  841 and 846 was not cognizable under  2241
A.