Bowe v. United States · ¶17

Nevertheless, the timing of this Court’s decisions, coupled with the timing of Bowe’s efforts to take advantage of them, have produced procedural complications that have so far prevented relief, leading to this appeal. Bowe, acting pro se, initially sought postconviction relief under §2255 in 2016, before the Court decided Davis, arguing that the residual clause is unconstitutionally vague. A District Court rejected Bowe’s claim, in part, because regardless of the residual clause’s constitutionality, attempted Hobbs Act robbery qualified as a crime of violence under §924(c)’s elements clause. App. 43.

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