Bowe v. United States · ¶102

AEDPA contains parallel directions for federal prisoners. When a federal prisoner seeks to challenge his conviction or sentence collaterally for the first time, he usually proceeds directly to district court under § 2255. But before he can pursue a second or successive challenge, it “must be certified as provided in section 2244 by a panel of the appropriate court of appeals.” § 2255(h). Through that cross-reference, then, federal prisoners seeking to bring second or successive collateral attacks are generally subject to the same rules as their state counterparts.

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