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Supreme Court Narrows AEDPA Limits on Federal Postconviction Motions in 5–4 Decision

The majority said Congress did not clearly extend state habeas restrictions to federal §2255 proceedings.

Overview

  • The Court held that §2244(b)(3)(E)’s certiorari bar does not prevent Supreme Court review of appellate denials authorizing successive motions by federal prisoners.
  • It further held that §2244(b)(1)’s repeat-claim dismissal rule applies to state §2254 petitions and does not govern federal §2255 motions.
  • Justice Sonia Sotomayor wrote the opinion for the Court, joined by Chief Justice Roberts and Justices Kagan, Kavanaugh, and Jackson, with Justice Jackson also filing a concurrence.
  • Justice Neil Gorsuch dissented, joined by Justices Alito and Thomas and by Justice Barrett in part, accusing the majority of creating a “broad new legal rule” that ignores AEDPA’s jurisdictional limits.
  • The case, the term’s first argued decision, resolves splits over AEDPA’s reach, shapes how courts handle successive §2255 filings and high court review of authorization denials, and arose from Michael Bowe’s repeated challenges to a §924(c) sentence.