Bowe v. United States · ¶54

If that were so, § 2255(h)'s cross-reference would also incorporate § 2244(b)(4). That provision directs district courts to review and “dismiss any claim presented in a second or successive application that the court of appeals has authorized . . . unless the applicant shows that the claim satisfes the requirements of” §2244. Put differently, once a second or successive application is certified, § 2244(b)(4) tells a district court to doublecheck that the application satisfes § 2244, including its gatekeeping requirements. Section 2244(b)(4), however, plainly falls outside the scope of § 2255(h)'s cross-reference because § 2244(b)(4) has nothing to do with how a filing is “certified as provided in section 2244 by a panel of the appropriate court of appeals.” § 2255(h). Thus, accepting the Government's argument that § 2255(h)'s cross-reference should be understood to incorporate any…

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