Case Summary:

The U.S. Supreme Court considered whether federal prisoners seeking postconviction relief under 28 U.S.C. § 2255 are not automatically barred by the “second or successive” claim-dismissal rule in § 2244(b)(1), a restriction that primarily governs state prisoners’ habeas applications under § 2254. The case arose from Michael Bowe’s attempt to challenge his mandatory consecutive 10‑year firearm sentence under § 924(c) in light of later decisions limiting what counts as a “crime of violence,” and the Court vacated and remanded after rejecting the government’s jurisdictional and procedural arguments that had allowed the Eleventh Circuit to block his new § 2255 motion.