Bowe v. United States · ¶16

Bowe did not stop there. A few months later, he again sought authorization to file a second or successive motion, again relying on Davis and Taylor. This time, Bowe also moved for initial hearing en banc. As relevant, he asked the Eleventh Circuit to overturn its precedent holding that § 2244(b)(1)'s old-claim bar applies to federal prisoners' successive § 2255 motions. In Bowe's view, that bar applies only to state prisoners, not federal prisoners like him. A three-judge panel dismissed Bowe's request for authorization, citing § 2244(b)(1), and the Eleventh Circuit denied Bowe's motion for initial hearing en banc.

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