--- title: "United States v. Holt" citation: "417 F.3d 1172 (11th Cir. 2005) (per curiam)" authority_id: "AUTH-CA11-HOLT-417-F3D-1172" authority_type: "case" jurisdiction: "federal_eleventh_circuit" precedential_status: "binding_in_ca11" official_url: "https://media.ca11.uscourts.gov/opinions/pub/files/200415848.pdf" url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA11-HOLT-417-F3D-1172/" legal_review: "2026-08-26" links_checked: "2026-10-15" links_available: 1 links_checked_count: 1 license: "CC BY 4.0" --- # United States v. Holt ## Holdings used - Audita querela may not be granted when the challenge is cognizable under § 2255; after recharacterization, an unauthorized successive motion remains outside district-court jurisdiction. ## Material limitation Binding only in the Eleventh Circuit and only for the bounded procedural postures in the linked claims. Official published opinion reviewed. Holt involved a constitutional sentencing attack by a federal prisoner with a prior § 2255 motion; it did not decide survival for claims outside § 2255's field. A comprehensive commercial citator was not run. ## Official source and pinpoints 417 F.3d 1172 (11th Cir. 2005) (per curiam), 417 F.3d 1174–75: ## Linked claims - `CLM-CIR11-007` ## Used in - [Eleventh Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/eleventh-circuit.md)