This case involves a pro se petition for a writ of habeas corpus under 28 U.S.C. § 2254 challenging a New York state guilty plea to armed robbery. The petitioner claimed ineffective assistance of counsel because his attorney incorrectly advised that a prior New Jersey conviction for aggravated assault on a police officer qualified as a predicate violent felony under New York law, causing him to accept a ten-year sentence as a second violent felony offender rather than pursuing a lower sentence. The federal court determined that the state court unreasonably applied the Strickland v. Washington standard. It reasoned that the attorney should have recognized that the New Jersey conviction was not analogous to the corresponding New York statute, as the petitioner had correctly identified through his own research, and that this misadvice prejudiced the petitioner in his plea decision. The court therefore granted the writ, permitting the petitioner to withdraw his plea.
This case involved two former union organizers who sued their employer, the New York City District Council of Carpenters, under the Labor-Management Reporting and Disclosure Act for alleged retaliatory discharge after they criticized union leadership about the financial condition of an officers' pension plan. The district court granted the defendant's motion for summary judgment. It held that the plaintiffs had executed releases barring their claims and that, even absent the releases, no reasonable jury could find their terminations were connected to any scheme to suppress dissent or that the terminations directly threatened union members' free speech rights.
This case involves a putative class action by U.S. purchasers against Chinese vitamin C manufacturers, alleging that the defendants formed a cartel through their industry chamber to fix prices and restrict output in violation of Section 1 of the Sherman Act and related Clayton Act provisions. The defendants moved for summary judgment, asserting defenses of foreign sovereign compulsion, act of state, and international comity on the ground that Chinese law and government directives required their conduct. The court denied the motion, holding that the relevant Chinese regulations did not actually mandate the price-fixing and output restrictions, that the factual record indicated voluntary agreements, and that the court was not required to defer to the Chinese Ministry of Commerce's contrary interpretation of its own laws.
This case involved the U.S. government's civil forfeiture action seeking to seize over $879,000 from accounts of PRP Restaurant, Inc. (a strip club) and its owner Robert Potenza, on the theory that cash deposits were structured in amounts under $10,000 to evade federal currency transaction reporting requirements. The government alleged over 100 such deposits between 2008 and 2009, supported by theories including transaction volume, a prior bank termination letter, and inferences of tax evasion from unreported cash flows. After a bench trial focused on knowledge and intent, the court ruled for the claimant, holding that the government failed to prove by a preponderance that Potenza acted with the requisite intent to evade the reporting rules. The reasoning emphasized that deposit patterns were consistent with innocent explanations like bill accumulation and business needs, that evidence from a disgruntled ex-employee was unreliable, and that the tax-evasion inference required an overly subtle understanding of the rules not shown to exist.
This case involved a condominium board suing developers under the Interstate Land Sales Full Disclosure Act (ILSA) for alleged misrepresentations about construction quality and defects in a converted factory building marketed as luxury units. The defendants moved to dismiss for lack of standing. The court granted the motion and dismissed the action, holding that the Board was not itself a purchaser entitled to sue under ILSA and did not qualify for associational standing because the claims did not affect all members in common and there were unresolved issues regarding res judicata and member consent. The court therefore concluded it lacked jurisdiction over the federal claims and did not reach the state-law claims or other arguments.
In Ellis v. United States, petitioner Amarley Ellis's brother sought to vacate his 1997 guilty plea to accessory after the fact under 18 U.S.C. § 3 for helping dispose of bodies and evidence after two murders committed to conceal the theft and fraudulent deposit of Social Security checks. The district court denied the 28 U.S.C. § 2255 petition to vacate the sentence, holding that the conviction qualified as an aggravated felony triggering deportation and that claims of ineffective assistance regarding immigration advice failed because any relevant legal changes were not retroactively applicable on collateral review. The court reasoned that the plea was knowing and voluntary based on the record, including explicit warnings about possible deportation, and that the underlying conduct met the statutory definition without requiring new substantive rules to apply.