Plain-English summary
Court rules §2244 limits don’t bar Supreme Court review of second-or-successive federal postconviction motions
The Supreme Court held that 28 U.S.C. §2244(b)(3)(E) does not prevent the Court from reviewing a federal prisoner’s request to file a second or successive §2255 motion, and that §2244(b)(1)’s dismissal rule does not apply to second-or-successive motions brought under the statute’s gatekeeping provision, §2255(h). The case was vacated and remanded to the lower court for further proceedings.
Why this matters
The decision clarifies limits on the procedural rules that courts use to police repeat postconviction petitions. It ensures the Supreme Court can review certain questions about whether a federal prisoner may bring a second or successive §2255 motion, and it narrows the circumstances in which earlier-dismissal rules automatically bar claims. That affects how and when federal prisoners can seek relief after conviction, and how lower courts treat requests to open a second postconviction proceeding.
Who may feel it
- Federal prisoners seeking to file a second or successive §2255 postconviction motion
- Federal appellate courts that screen and authorize successive habeas petitions
- Defense attorneys and federal public defenders handling postconviction relief
- Prosecutors and the Department of Justice defending convictions in collateral review
Key questions
- Does §2244(b)(3)(E) bar the Supreme Court from reviewing a federal prisoner’s request to file a second or successive §2255 motion?