---
title: "Bowe v. United States"
citation: "Bowe v. United States, 607 U.S. 13 (2026)"
authority_id: "AUTH-SCOTUS-BOWE-607-US-13"
authority_type: "case"
jurisdiction: "federal_nationwide"
precedential_status: "binding"
official_url: "https://www.supremecourt.gov/opinions/25pdf/607us1r04_n7ip.pdf"
url: "https://jason93.com/legal/federal-process/authorities/AUTH-SCOTUS-BOWE-607-US-13/"
legal_review: "2026-08-24"
links_checked: "2026-10-15"
links_available: 1
links_checked_count: 1
license: "CC BY 4.0"
---

# Bowe v. United States

## Holdings

1. Section 2244(b)(3)(E) does not bar Supreme Court certiorari review of a federal prisoner's request to file a successive § 2255 motion.
2. Section 2244(b)(1) does not apply to successive motions filed by federal prisoners under § 2255(h).

## Disposition

The Court vacated and remanded. It left the Eleventh Circuit to decide authorization under the correct standard.

## Material limitations

The Court distinguished § 2244(b)(3)(E)'s certiorari language from its rehearing language; it did not hold that federal prisoners have a right to panel or en banc rehearing of authorization decisions. Every successive federal claim still must meet § 2255(h), and the opinion did not itself authorize Bowe's motion.

## Official source and pinpoint

Supreme Court preliminary print, 607 U.S. 13, especially 19–38: <https://www.supremecourt.gov/opinions/25pdf/607us1r04_n7ip.pdf>


## Used in

- [28 U.S.C. §§ 2244 and 2255(h) — Successive-Application Gatekeeping](https://jason93.com/legal/federal-process/modules/60-post-conviction/2244-2255-successive-gatekeeping.md)
- [Later Section 2255 Filings — Classification and Authorization](https://jason93.com/legal/federal-process/modules/60-post-conviction/2255-later-filings-classification-and-authorization.md)