Bowe v. United States · ¶104

When Mr. Bowe sought permission to bring his latest collateral attack, the Eleventh Circuit demurred. Because he had pursued his Davis claim three times before, the court held that his latest filing represented an impermissible do- over claim barred by § 2244(b)(1). Now, Mr. Bowe asks us to reverse the Eleventh Circuit's decision. Yes, he concedes, AEDPA bars state prisoners from pursuing do-over claims. But, he insists, federal prisoners are different. They (and they alone) are free to bring the same claim in district court over and over again.

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