---
title: "United States v. Muhammad"
citation: "16 F.4th 126 (4th Cir. 2021)"
authority_id: "AUTH-CA4-MUHAMMAD-16-F4TH-126"
authority_type: "case"
jurisdiction: "federal_fourth_circuit"
precedential_status: "binding_in_ca4"
official_url: "https://www.ca4.uscourts.gov/opinions/207520.P.pdf"
url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA4-MUHAMMAD-16-F4TH-126/"
legal_review: "2026-08-25"
links_checked: "2026-10-15"
links_available: 1
links_checked_count: 1
license: "CC BY 4.0"
---

# United States v. Muhammad

## Holdings used

- The filing threshold is nonjurisdictional and waivable; after a warden request, full exhaustion or 30 days, whichever is earlier, permits defendant filing even after an early denial.

## Material limitation

Binding only in the Fourth Circuit and only for the bounded procedural postures in the linked claims. Official published opinion reviewed. The holding is limited to the statutory threshold and alternative routes; no issue-exhaustion or merits proposition is adopted. A comprehensive commercial citator was not run.

## Official source and pinpoints

16 F.4th 126 (4th Cir. 2021), 16 F.4th 129–31: <https://www.ca4.uscourts.gov/opinions/207520.P.pdf>

## Linked claims

- `CLM-CIR4-003`


## Used in

- [Fourth Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/fourth-circuit.md)
