Bowe v. United States · ¶126

His theory runs this way. Section 2255(h) instructs that a federal prisoner’s second or successive attack “must be certified as provided in section 2244.” That language, Mr. Bowe submits, sweeps in only those parts of §2244 that address how an appellate panel goes about certifying a second or successive filing. And it does not sweep in subparagraph (E) because—unlike all of §2244(b)(3)’s other subparagraphs—it does not “provide” for certification.

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