Jon Raymond CARRIGAN, Petitioner-Appellant, v. UNITED STATES of America, Respondent-Appellee, 196 F. App'x 269

PER CURIAM: Jon Raymond Carrigan, federal prisoner # 26552-177, has filed a request for a certificate of probable cause, which is now known as a certificate of appealability (COA), to appeal the district court’s dismissal of his 28 U.S.C. § 2241 petition. Carrigan challenges his conviction and sentence for conspiracy to possess pseudoephedrine with the intent to manufacture methamphetamine. The district court dismissed the petition because Carrigan did not qualify to proceed under the “savings clause” of 28 U.S.C. § 2255.

Because Carrigan is a federal prisoner seeking to proceed under § 2241, he is not required to obtain a COA. See Jeffers v. Chandler, 253 F.3d 827, 830 (5th Cir.2001). Carrigan does not address the basis for the district court’s conclusion that his § 2241 petition should be dismissed. Although pro se briefs are liberally construed, even pro se litigants must brief arguments to preserve them. Yohey v. Collins, 985 F.2d 222, 224-25 (5th Cir.1993).

Because Carrigan has not addressed the basis for the district court’s dismissal of his § 2241 petition, he has abandoned any argument that the district court erred when it dismissed his § 2241 petition for lack of jurisdiction. See Brinkmann v. Dallas County Deputy Sheriff Abner, 813 F.2d 744, 748 (5th Cir.1987). AFFIRMED. Pursuant to 5th Cir. R. 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5th Cir. R. 47.5.4.