Bowe v. United States

The Court ruled that it may review whether a federal prisoner can file a second or successive motion to challenge a conviction or sentence. It also ruled that the rule requiring dismissal of repeat claims in state-prisoner habeas cases does not apply to federal prisoners' motions under §2255, then vacated the Eleventh Circuit's decision and sent the case back.

Justice Sotomayor wrote the 5–4 opinion, joined by Chief Justice Roberts and Justices Kagan and Kavanaugh; Justice Jackson concurred; Justices Gorsuch, Thomas, Alito, and Barrett dissented.

Majority

Sotomayor

Roberts

Kagan

Jackson

Kavanaugh

Dissent

Gorsuch

Thomas

Alito

Barrett

“Section 2244(b)(1) does not apply to second or successive motions filed under §2255(h) by federal prisoners challenging their convictions or sentences.”

Federal prisoners seeking to file another challenge to a conviction or sentence are affected. For example, a prisoner whose request to file a second §2255 motion is denied may seek Supreme Court review of that decision.

The case returns to the Eleventh Circuit for further proceedings under the Court's decision. Lower courts must apply the separate rules for federal prisoners' §2255 motions rather than importing the state-prisoner repeat-claim rule.

The Court said it can review requests to file second or successive §2255 motions. It said the state-prisoner repeat-claim rule does not govern those federal-prisoner motions.

Federal prisoners seeking another court challenge to a conviction or sentence under §2255 are affected. Courts must use the rules specifically governing those motions.

The Eleventh Circuit will handle the case again under the Supreme Court's decision. Other lower courts must follow the Court's interpretation in similar cases.