Bowe v. United States: Jurisdiction over Federal Successive Habeas Motions

In the 2026 decision Bowe v. United States, the Supreme Court clarified the procedural hurdles federal prisoners face when seeking postconviction relief. The Court ruled that federal inmates are not barred from seeking certiorari review by the Supreme Court after an appellate panel denies them permission to file a successive motion. This distinguishes them from state prisoners, for whom such denials are legally final and unreviewable by the high court. Furthermore, the Court held that a specific statutory "old-claim bar," which requires the dismissal of repetitive claims previously raised, applies only to state prisoners and not to federal ones. Writing for the majority, Justice Sotomayor emphasized that while the law cross-references certain procedures, it does not strip the Court of its jurisdiction over federal cases. The ruling effectively resolves a circuit split, ensuring that federal prisoners can continue to litigate claims based on new legal developments even if they were previously presented. However, the dissent argued that the majority ignored the plain text of the law, which aimed to limit repetitive litigation and promote finality for all inmates.