Bowev.United States
A federal prisoner sought authorization to file another Section 2255 motion after intervening decisions undermined the predicate for his firearm convictions. The Eleventh Circuit applied 28 U.S.C. § 2244(b)(1)’s bar on previously presented claims and treated its authorization ruling as insulated from Supreme Court review. The Supreme Court held that § 2244(b)(3)(E)’s certiorari bar does not apply to federal prisoners’ Section 2255 motions and that § 2244(b)(1)’s old-claim bar likewise governs state habeas applications, not federal-prisoner motions. The judgment was reversed and the case remanded for the authorization request to be considered under the provisions that actually govern successive § 2255 motions.
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