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 Bowe's case concerning his efforts to obtain postconviction relief from a mandatory sentence under §924(c). The Court determined its jurisdiction to review federal prisoners' requests for successive §2255 motions and clarified that §2244(b)(1)'s old-claim bar does not apply to federal prisoners. The case was vacated and remanded for further proceedings under the correct standard.
Holding
The single most important “bottom line” of what the Court decided in Bowe v. United States.
The Court held that it has jurisdiction to review federal prisoners' requests to file successive §2255 motions and that §2244(b)(1) does not apply to such 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.
-
Why Void for Vagueness is relevant to Bowe v. United States
The case discusses whether the residual clause of §924(c) is unconstitutionally vague, referencing the decision in United States v. Davis.
Syllabus excerpt (verbatim)See United States v. Davis, 588 U. S. 445, 470 (residual clause void for vagueness);
-
Why Judicial Review is relevant to Bowe v. United States
The Court examines its jurisdiction to review decisions regarding second or successive motions under §2255.
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.
-
Why Procedural Due Process is relevant to Bowe v. United States
The case involves procedural rules governing postconviction relief and 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.
Section 2244(b)(1)’s old-claim bar applies only to state prisoners.
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 2255(h)’s cross-reference does not provide the clear indication of intent required to strip the Court of jurisdiction.
