Bowe v. United States · ¶80

For these reasons, §2244(b)(1) does not apply to second or successive motions filed by federal prisoners challenging their convictions or sentences under §2255(h). The Court leaves it to the Eleventh Circuit to determine in the first instance whether Bowe should receive authorization to file a second or successive motion under the correct standard. The judgment below is vacated, and the case is remanded for further proceedings consistent with this opinion.

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