---
title: "United States v. Barrett"
citation: "178 F.3d 34 (1st Cir. 1999)"
authority_id: "AUTH-CA1-BARRETT-178-F3D-34"
authority_type: "case"
jurisdiction: "federal_first_circuit"
precedential_status: "binding_in_ca1"
url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA1-BARRETT-178-F3D-34/"
legal_review: "2026-08-25"
links_checked: "2026-10-15"
links_available: 1
links_checked_count: 1
license: "CC BY 4.0"
---

# United States v. Barrett

## Holdings used

- COA and appellate preclearance requirements do not directly apply to a federal prisoner's claim actually proceeding under § 2241; classification remains separate.

## Material limitation

Binding only in the First Circuit and only for the bounded procedural postures in the linked claims. Published precedential full opinion reviewed from a public full-text mirror after no historical official opinion file was located. The mixed alternative posture is preserved, and no saving-clause merits proposition is adopted. A comprehensive commercial citator was not run.

## Official source and pinpoints

178 F.3d 34 (1st Cir. 1999), 178 F.3d 42: <https://www.courtlistener.com/opinion/198488/united-states-v-barrett/>

## Linked claims

- `CLM-CIR1-003`


## Used in

- [First Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/first-circuit.md)
