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In re Bowe

Updated Sep 19, 2026

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.

Illustration for In re Bowe
Conceptual illustration · AI-generated

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

3

Docket activity

6
  • New analysis added

    Sep 19, 2026 · Court records

  • AI analysis generated: Case Briefing

    Sep 19, 2026 · Generated

  • AI analysis generated: Decision Record

    Sep 19, 2026 · Generated

  • Opinion added: In re Bowe

    Feb 20, 2024 · Court records

  • Opinion added: Opinion

    Feb 20, 2024 · Court records

Show 1 more
  • Brief added: Petition

    Jun 23, 2023 · Court records

More questions

3
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.

Checked Sep 19, 2026Methodology

Court records and filings

Reporting and analysis