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Bowe v. United States · ¶68

This specific reference to § 2254 was deliberate: Elsewhere in this very section, § 2244 acknowledges § 2255. See § 2244(a) (referencing § 2255); see also §§ 2253(c)(1)(A)–(B) (distinguishing a “final order” in a “habeas corpus proceeding in which the detention complained of arises out of process issued by a State court” from one “in a proceeding under section 2255”); § 2266(a) (distinguishing an “application under section 2254” from a “motion under section 2255”). A cardinal rule of statutory interpretation teaches that “when we're engaged in the business of interpreting statutes[,] we presume differences in language like this convey differences in meaning.” Henson v. Santander Consumer USA Inc., 582 U. S. 79, 86 (2017). Thus, by its plain terms, § 2244(b)(1)'s old-claim bar applies only to state prisoners.
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