When, in the pendency of collateral post-conviction challenges, a state habeas that was subsequently challenged in federal habeas is re-reviewed by the state sua sponte, an attempt to resuscitate the federal habeas claim by a 60(d) motion is properly construed as a second-or-sucessive habeas petition, and is subject to those statutory limits.
http://www.ca5.uscourts.gov/opinions/pub/16/16-30279-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.