Michael St. Clair v. Willis Pettit, Warden

Petitioner is a state prisoner seeking habeas corpus relief attacking an Executive Agreement regarding his physical custody in Oklahoma. Thus, he proceeded under the general habeas corpus statute of 28 U.S.C. § 2241, rather than 28 U.S.C. § 2254 which deals with state prisoners attacking their underlying criminal convictions and sentences. However, the Tenth Circuit held that the limitations period of 28 U.S.C. § 2244 applies to petitions filed under 2241. There is a circuit split on this issue, with the Second, Fourth, Fifth, Ninth, and Tenth Circuits holding that the limitations period of 2244 does apply to 2241 petitions; and the Seventh Circuit concluding the opposite. This Court recently decided Bowe v. United States, No. 24-5438 (U.S., January 9, 2026), holding that certiorari provisions of 2244 do not apply to 2255 petitions. The question presented is: Does the limitations provision of 2244 apply to 2241 petitions, and can the holding of the Tenth Circuit and the majority of circuits deciding the issue be squared with the legal framework of this Court’s decision in Bowe concerning statutory construction and congressional intent?