2018—So much for Congress’s restriction, enacted in 1996, providing that a federal prisoner may file a second habeas petition under 28 U.S.C. 2255 only upon a showing of new evidence of innocence or a new rule of constitutional law from the Supreme Court. In United States v. Wheeler, a Fourth Circuit panel holds that a new rule of law, whether constitutional or statutory, from the court of appeals can enable a federal prisoner to bypass Congress’s restriction.