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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