Habeas. It’s a twisted procedural maze. It feels like there is no escape. And a second or successive petition is even harder (nigh impossible) to win. But when is a petition successive and when is it an amendment to an original petition? If a petitioner amends the petition while the original petition is on appeal, is it an amended initial petition or a second/successive? The circuits are split, and the Supreme Court will break the tie and decide when a petition becomes second or successive under 28 U.S.C. § 2244(b)(2) when amended while on appeal.