Bowe v. United States · ¶15
Then, after Taylor was decided in 2022, Bowe once again sought permission from the Eleventh Circuit to file a second or successive motion. This time, Bowe argued that under Davis and Taylor, none of his convictions qualified as a predicate “crime of violence.” A three-judge panel dismissed the part of Bowe's request that rested on Davis, reasoning that because the claim was “presented in a prior application” to file a second or successive motion, the panel lacked jurisdiction over it under § 2244(b)(1). App. 59–60. The panel also denied the part of Bowe's request that rested on Taylor, concluding that Taylor did not announce a new constitutional rule as needed to secure relief under § 2255(h)(2). App. 59–60.Read in context ›
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