Bowe v. United States · ¶32

In the Government's view, the cross-reference captures all of §§ 2244(b)(3) and (b)(4), including the certiorari bar in § 2244(b)(3)(E). Although the Government is correct that the cross-reference incorporates some of the provisions it identifes, the Government is wrong that it also incorporates the certiorari bar. That is because the cross-reference, coupled with its context, does not provide the clear indication needed to strip this Court of jurisdiction.

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