The miscarriage-of-justice gateway excuses a habeas petitioner from complying with certain procedural hurdles like AEDPA's statute of limitations if, for example, she can prove that she is actually innocent.

The question presented in this case is whether the miscarriage-of-justice gateway applies only where a petitioner can prove that she is "morall[ly]" or "completely" innocent of any crime, as the court below and Eleventh Circuit have held; or whether it is sufficient for her to prove her innocence of the offense holding her in custody, as the Second, Third, Fourth, Sixth, and Eighth Circuits have held—in this case, because the convicting court lacked subject-matter jurisdiction, a fundamental defect historically remediable in habeas without the application of procedural bars to relief.

Whether the actual-innocence gateway applies only where a petitioner can prove that she is 'morall[ly]' or 'completely' innocent of any crime, or whether it is sufficient for her to prove her innocence of the offense holding her in custody