Bowe v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Bowe v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Bowe v. United States.
The Supreme Court reviewed Michael S. Bowe's efforts to obtain postconviction relief from a mandatory 10-year sentence under § 924(c). The Court examined whether § 2244(b)(3)(E) applies to federal prisoners, impacting their ability to file successive motions. The decision addressed the procedural differences between state and federal prisoners under AEDPA.
Holding
The single most important “bottom line” of what the Court decided in Bowe v. United States.
The Court held that § 2244(b)(3)(E) does not bar the Court's review of federal prisoners' requests to file successive § 2255 motions.
Constitutional Concepts
These are the Constitution-related themes that appear in Bowe v. United States. Click a concept to see other cases that involve the same idea.
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Why Void for Vagueness is relevant to Bowe v. United States
The case involves the question of whether certain statutory provisions are unconstitutionally vague, impacting Bowe's conviction under § 924(c).
Syllabus excerpt (verbatim)decisions issued years after Bowe's conviction call into question whether either clause can support his § 924(c) conviction. See United States v. Davis, 588 U. S. 445, 470 (residual clause void for vagueness)
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Why Judicial Review is relevant to Bowe v. United States
The Court is exercising its power to review and interpret the applicability of statutory provisions to federal prisoners, impacting the jurisdiction and procedures for postconviction relief.
Syllabus excerpt (verbatim)The Court has jurisdiction because § 2244(b)(3)(E) does not bar this Court's review of a federal prisoner's request to file a second or successive § 2255 motion.
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Why Procedural Due Process is relevant to Bowe v. United States
The case addresses the procedural requirements and rights of federal prisoners seeking postconviction relief, including the certification process for successive motions.
Syllabus excerpt (verbatim)A comprehensive statutory scheme governs when and how state and federal prisoners can seek postconviction relief in federal court.
Key Quotes
Short excerpts from the syllabus in Bowe v. United States that support the summary and concepts above.
The Court has jurisdiction because § 2244(b)(3)(E) does not bar this Court's review of a federal prisoner's request to file a second or successive § 2255 motion.
Section 2244(b)(1) does not apply to second or successive motions filed under § 2255(h) by federal prisoners challenging their convictions or sentences.
The language of the cross-reference is both narrow and specific.