The case involved a Jordanian permanent resident who pled guilty in 1984 to conspiracy and possession with intent to distribute cocaine. He later faced deportation proceedings and petitioned for writs of error coram nobis and audita querela, alleging ineffective assistance of counsel because his attorney wrongly assured him that a judicial recommendation against deportation would shield him from removal under then-existing immigration law. The court granted the petition, holding that counsel's affirmative misrepresentations about the statutory limits of the recommendation constituted a fundamental Sixth Amendment error in the plea process. It further found that the petitioner had diligently sought relief, continued to suffer severe collateral consequences, and had no other available remedies.
This case concerns two consolidated actions brought by residents of the Massachusetts Treatment Center for Sexually Dangerous Persons challenging conditions of confinement and adequacy of treatment under the 1947 state law providing for civil commitment of such persons. In 1974, the district court entered consent decrees requiring the facility to operate primarily under Department of Mental Health authority, provide the least restrictive conditions possible, improve physical plant and programs, and avoid punitive solitary confinement. After twenty-five years of litigation, the defendants renewed their motion to vacate or terminate the decrees. The court reviewed the deplorable conditions that originally prompted the decrees and noted the intervening enactment of the Prison Litigation Reform Act, which limits federal courts' authority to grant or maintain prospective relief in cases involving prison conditions and sets standards for terminating existing consent decrees.
This case concerns whether Massachusetts could validly adopt and enforce portions of California's zero-emission vehicle (ZEV) sales mandate under section 177 of the Clean Air Act, which permits other states to copy California motor vehicle emission standards but requires those standards to be identical and adopted with sufficient lead time. The auto manufacturers challenged the Massachusetts regulations after California repealed its ZEV requirements for model years 1998 and 2000 and replaced them with memoranda of agreement. The court granted summary judgment, holding that Massachusetts' amended ZEV mandate was not identical to the California standards in effect at the time of adoption and therefore fell outside the narrow exception to federal preemption in section 209(a). The reasoning centered on the statutory text of sections 177 and 209, the history of California's waiver, and the requirement that states may adopt only one of two permissible regulatory schemes (federal or California) to avoid creating a prohibited third car.
The case involved James Mazzarella, a USPS custodian with a psychiatric disability, who was terminated after a December 1990 incident where he engaged in violent and destructive behavior at work. He sued the USPS alleging handicap discrimination under the Rehabilitation Act and a violation of his constitutional property rights. The court granted summary judgment to the defendants, finding that Mazzarella was dismissed due to his misconduct rather than his disability, and that he failed to show he was an otherwise qualified individual under the Act. Additionally, the constitutional claim was dismissed because statutory remedies exist for such discrimination claims and no procedural deficiencies were alleged.
This case concerned whether the Massachusetts Department of Revenue could keep funds it levied from a bankrupt company's bank account to satisfy unpaid withheld state income taxes, or whether those funds were recoverable by the bankruptcy trustee as an avoidable preference under 11 U.S.C. § 547. The district court held that Mass. Gen. Laws ch. 62B, § 5 creates a trust for withheld taxes that parallels the federal trust in 26 U.S.C. § 7501, making the Supreme Court's decision in Begier v. IRS controlling. Under Begier, the withheld taxes are not property of the debtor, a trust arises upon payment of net wages without need for segregation or strict tracing of specific dollars, and the debtor's ability to pay the taxes satisfies the required nexus to the trust funds. The court therefore vacated the bankruptcy court's denial of the motion to dismiss and remanded for further proceedings consistent with that analysis.
The case involved investors in the New America High Income Fund who sued the Fund, its officers, directors, and underwriters, claiming that the prospectus for the Fund's 1988 initial public offering contained misrepresentations about the historical performance, yields, and default rates of high yield bonds, in violation of sections 11 and 12(2) of the Securities Act of 1933. After earlier claims were dismissed, the remaining allegations centered on whether the prospectus painted an overly optimistic picture of the bond market without adequate disclosure of risks. The defendants moved for summary judgment. The court applied the Federal Rules of Civil Procedure standard requiring the absence of any genuine issue of material fact and concluded that summary judgment was appropriate because the prospectus disclosures were accurate and included an explicit disclaimer that past performance did not guarantee future results.
