In re Bowe
In brief
The Supreme Court declined to hear In re Bowe and left unanswered whether § 2244(b)(1) applies to federal prisoners.
- Where it stands
- Decided
Decided · February 20, 2024 · Opinion by Justice Sotomayor
- What it’s about
- This case involves whether a specific legal restriction on successive habeas corpus petitions applies to federal prisoners. The government conceded that the restriction under Section 2244(b)(1) only applies to state prisoners.
- Who it affects
- The denial leaves that legal question unanswered in this case. It did not decide whether the restriction applies to federal prisoners or endorse either side's position.
Summary: written with AI from the case record.

What it's about
Federal and state prisoners use different federal procedures to challenge convictions, and this case asked whether a repeat-filing limit written for state cases also applies to federal prisoners.
Question presented
Whether a specific legal restriction on successive habeas corpus petitions applies to federal prisoners.
What the Court decided
Holding
Petition DENIED. Statement of Justice Sotomayor, with whom Justice Jackson joins, respecting the denial of the petition for a writ of habeas corpus. (Detached Opinion )
The vote
- Majority author
- Sonia Sotomayor
What's next
The Supreme Court's docket action is finished. This action identifies no further step resolving the question in this case.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Opinion added: In re Bowe
Opinion added: Opinion
Show 1 moreShow fewer
Brief added: Petition
More questions
- What did the Supreme Court do in In re Bowe?
- The Court declined review by denying the petition. It did not decide whether § 2244(b)(1) applies to federal prisoners.
- What question did In re Bowe raise?
- It asked whether § 2244(b)(1)'s limit on certain repeat habeas petitions applies to federal prisoners.
- Was either side the winner in In re Bowe?
- No. The Court did not decide the legal question or endorse either side's position.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.