Bowe v. United States

Michael S. Bowe was sentenced to 24 years in federal prison after pleading guilty to conspiracy of Hobbs Act robbery, attempted Hobbs Act robbery, and using a firearm during a "crime of violence". The conviction of the third charge depended on at least one of Bowe's other charges being classified as a crime of violence. Bowe attempted to obtain postconviction relief to overturn his third charge after the Supreme Court stated that one of the clauses used in his conviction was unconstitutional, but he was denied as another still found him guilty. After the Supreme Court ruled that to be unconstitutional as well, he tried to file a second motion but was blocked in lower courts. This brought the question of whether or not the federal rule that limits second or successive habeas petitions was applicable to federal prisoners. It also questioned if the Supreme Court was allowed to review the Court of Appeals's denial of a federal prisoners petition.

The majority opinion of the Court was that the federal rule does not apply to federal prisoners and only apply to state prisoners, therefore, it does not apply to Bowe. The Supreme Court affirmed their authority over the case and stated that Congress would need to explicitly state limitation in jurisdiction for them to be limited.

Link to full text: https://www.supremecourt.gov/opinions/25pdf/24-5438_o7kq.pdf

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