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Bowe v. United States · ¶101

That brings us to Michael Bowe. After shooting two guards while trying to rob an armored vehicle in 2008, he pleaded guilty to three federal crimes. Since then, he has pursued five nearly identical postconviction challenges. In each, Mr. Bowe has asserted that one of the statutes under which he was convicted, 18 U. S. C. §924(c), is unconstitutional under our void-for-vagueness doctrine. And in all but the first of his challenges, Mr. Bowe has centered his argument around the same case: United States v. Davis, 588 U. S. 445 (2019).
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