---
title: "United States v. Keller"
citation: "2 F.4th 1278 (9th Cir. 2021)"
authority_id: "AUTH-CA9-KELLER-2-F4TH-1278"
authority_type: "case"
jurisdiction: "federal_ninth_circuit"
precedential_status: "binding_in_ca9"
official_url: "https://cdn.ca9.uscourts.gov/datastore/opinions/2021/07/01/20-50247.pdf"
url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA9-KELLER-2-F4TH-1278/"
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. Keller

## Holdings used

- The filing prerequisite is mandatory when invoked; a changed-circumstances renewed motion required a new qualifying BOP request, and the defect was not cured by 30 days passing during pendency.

## Material limitation

Binding only in the Ninth Circuit and only for the bounded procedural postures in the linked claims. Official published opinion and public full-text mirror reviewed. The renewed-motion holding is tied to changed circumstances and is not generalized into universal issue exhaustion. A comprehensive commercial citator was not run.

## Official source and pinpoints

2 F.4th 1278 (9th Cir. 2021), 2 F.4th 1281–84: <https://cdn.ca9.uscourts.gov/datastore/opinions/2021/07/01/20-50247.pdf>

## Linked claims

- `CLM-CIR9-006`


## Used in

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