Bowe v. United States

Summary

The Court held that it has jurisdiction to review the Eleventh Circuit’s denial of Bowe’s authorization to file a second §2255 motion because §2244(b)(3)(E) does not bar certiorari review of federal prisoners, and that §2244(b)(1)’s old‑claim bar applies only to state prisoners, so it does not apply to Bowe’s §2255 motion. The judgment below was vacated and the case remanded for further proceedings.