type: timeline_event
The Supreme Court ruled 5-4 in Bowe v. United States that the Antiterrorism and Effective Death Penalty Act's (AEDPA) bar on successive habeas claims does not apply to federal prisoners filing Section 2255 motions. Justice Sotomayor wrote for a majority including Chief Justice Roberts and Justices Kagan, Kavanaugh, and Jackson, holding that Section 2244(b)(1)'s "old-claim bar" applies only to state prisoners by its plain terms.
The case involved Michael Bowe, convicted in 2008 under 18 U.S.C. § 924(c) with a mandatory consecutive ten-year sentence, whose conviction became invalid after the Supreme Court struck down the statute's "residual clause" as unconstitutionally vague in 2019. The Eleventh Circuit had denied his habeas petition based on AEDPA restrictions, joining five other circuits in applying state prisoner limitations to federal inmates.
Justice Gorsuch dissented, joined by Justices Alito and Thomas and partially by Justice Barrett, arguing the Court lacked jurisdiction and criticizing the majority for creating "a broad new legal rule that even express limitations on our certiorari jurisdiction are unenforceable absent a clear statement." The decision resolves a 6-3 circuit split but highlights ongoing tensions over habeas corpus access and AEDPA's reach in restricting post-conviction relief for wrongfully imprisoned defendants.