Michael Bowe, Petitioner v. United States

This case asked whether federal prisoners face the same repeat-claim limits as state prisoners. The Court held that two AEDPA limits did not apply to federal prisoners’ Section 2255 motions to vacate (set aside) sentences. It vacated the Eleventh Circuit’s decision and sent the case back.

Result

Vacated

This affects federal prisoners seeking repeat motions to vacate (cancel) their sentences. The Court said earlier-claim dismissal rules for state prisoners do not automatically govern them. For example, Bowe can keep pursuing review of his 10-year consecutive firearm sentence. Next, more federal prisoners may ask for certiorari (Supreme Court review) after appeals-court authorization decisions. But they still must

Not official Court text.

Vote split

5-4

Majority author

Sonia Sotomayor