Habeas
When a state prisoner's speedy trial Federal Habeas claim shifts from a pretrial Habeas to a postconviction Habeas during the pendency of the appeal, the appeals court must dismiss for lack of jurisdiction.
(The only issue in the COA was the threshold question of whether the pretrial Habeas standard for state exhaustion was met.)
http://www.ca5.uscourts.gov/opinions/pub/15/15-20275-CV0.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.