In this case, Michael Murray petitioned for a writ of coram nobis to challenge the length of his 1994 federal sentence for marijuana conspiracy and distribution, arguing that his prior 1984 conviction for similar conduct was invalid due to alleged FBI misconduct and false testimony tied to the Whitey Bulger scandal, which he claimed improperly influenced the sentence. The 1984 conviction had been affirmed on appeal after remand from the Supreme Court on Fourth Amendment and Speedy Trial Act issues, and Murray's sentence was later reduced by agreement. The court denied the petition without an evidentiary hearing, holding that Murray failed to show any fundamental error in the 1984 proceedings because any potential factual inaccuracies were immaterial to the conviction and his claims amounted to unsupported speculation. The decision rested on the high bar for coram nobis relief and the lack of evidence that the 1984 conviction would have been overturned.
In Carrasquillo v. United States, the petitioner filed a habeas petition under 28 U.S.C. § 2255 claiming that his counsel was ineffective for failing to shield him from government pressure during a post-plea proffer, which led to an admission of gun possession, and that the pre-sentence report inaccurately described his drinking. The district court had summarily dismissed the petition, noting that Carrasquillo failed to show prejudice, and on limited remand from the First Circuit, the court clarified its reasoning. The court decided that the petition was properly dismissed because Carrasquillo suffered no constitutional prejudice, as neither the gun possession admission nor his drinking history influenced the imposed sentence. The core reasoning was that the sentence was determined primarily by the need for proportionality among co-defendants' culpability levels under 18 U.S.C. § 3553(a) factors, rather than by the challenged elements, and no sentencing enhancement for the gun was ultimately applied.
In Rivera v. Astrue, the plaintiff sought judicial review under 42 U.S.C. § 405(g) of the Social Security Commissioner's denial of his applications for SSDI and SSI benefits, arguing that the hearing officer improperly weighed medical opinions by favoring state-agency psychologists over his treating clinician and failed to apply the proper standards for evaluating pain and credibility under Avery v. Secretary of Health & Human Servs. The court denied Rivera's motion to reverse and granted the Commissioner's motion to affirm the denial of benefits. The decision rested on the conclusion that substantial evidence supported the hearing officer's findings, including appropriate weighting of opinions where inconsistencies existed and credibility determinations based on Rivera's reported daily activities, work history, and functional assessments that indicated greater capabilities than claimed.
The Dixons sued Wells Fargo seeking to enjoin foreclosure on their home, specific performance of an alleged oral agreement to modify their mortgage loan, and damages, claiming they relied on the bank's instructions to stop payments in anticipation of a modification. Wells Fargo moved to dismiss, arguing that the promissory estoppel allegations were insufficiently definite and that any state-law claim was preempted by the Home Owners’ Loan Act and its regulations. Having already dismissed the contract claim for inadequate pleading and denied remand, the court took under advisement whether the complaint plausibly alleged a binding promise and reasonable detrimental reliance under promissory estoppel, as well as the scope of HOLA preemption for claims directly affecting federal savings banks' lending practices.
The case involved doctors Christof Westenfelder and Axel Zander suing AlloCure Inc. and related parties after their termination, asserting that AlloCure breached a Stock Restriction Agreement governing repurchase of their company shares. The plaintiffs moved for a preliminary injunction to bar arbitration of that claim, while AlloCure moved to compel arbitration under a clause in separate Consulting Agreements the parties had signed earlier. The court allowed the injunction, denied the motion to compel, and held that the claim was not subject to arbitration. It reasoned that the broad arbitration clause covered only disputes arising out of or relating to the Consulting Agreements, that the stock-repurchase claim did not implicate obligations under those agreements, and that parties cannot be forced to arbitrate absent consent even when multiple contracts are connected by the same transaction.
The case involves plaintiff Michael Mahon suing the United States and others for severe injuries from falling off a portico at the Commandant's House in the Boston National Historic Park, which he attributes to defective guardrails. The United States moved to dismiss under the discretionary function exception to the Federal Tort Claims Act's waiver of sovereign immunity. The court initially granted the motion but, on reconsideration after reviewing a concession contract between the National Park Service and a management company, vacated the dismissal and denied the motion. The core reasoning is that Service management policies impose a specific, non-discretionary duty to review and approve the concessioner's risk management plan, and the alleged failure to do so could support liability even if decisions about the guardrails themselves remain discretionary.
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