It was decided differently in 2 different Circuits post Woollard
With the DC ruling in Wrenn, we now have a split that SCOTUS can rule on. Woolard was decided before Wrenn, so it doesn't create the split needed. Previously decided cases can't be used to apply for CERT as I understand this.
With the DC ruling in Wrenn, we now have a split that SCOTUS can rule on. Woolard was decided before Wrenn, so it doesn't create the split needed. Previously decided cases can't be used to apply for CERT as I understand this.