Back to the Future: Permitting Habeas Petitions Based on Intervening Retroactive Case Law to Alter Convictions and Sentences

In 1948, Congress enacted 28 U.S.C. § 2255, which authorizes a motion for federal prisoners to “vacate, set aside or correct” their sentences, with the goal of improving judicial efficiency in collateral review. Section 2255(e), known as the “savings clause,” allows federal inmates to challenge the validity of their imprisonments with writs of habeas corpus if § 2255 motions are “inadequate or ineffective to test the legality of [their] detention[s].” Due to the U.S. Supreme Court’s and Congress’s silence regarding what suffices as “inadequate or ineffective,” the circuit courts have adopted varied standards. The Sixth and Seventh Circuits hold that prisoners can use the savings clause to challenge their convictions or sentences based on new retroactive case law. On the other hand, the Tenth and Eleventh Circuits prejudice prisoners by prohibiting them from challenging their convictions or sentences based on new case law. Recently, the Fourth Circuit expanded the circuit split by agreeing with the Sixth and Seventh Circuits in United States v. Wheeler. A petition for a writ of certiorari in Wheeler is currently pending before the Supreme Court. This Note examines the circuits’ different standards and contends that the circuits that foreclose savings clause challenges impermissibly curtail prisoners’ rights. Further, this Note argues that the Supreme Court must define the scope of the savings clause to permit prisoners to challenge their convictions and sentences under the provision

Obstacles in Human Service Work with Teen Mothers

Research has shown that it is extremely beneficial for teen mothers to have support during their pregnancy and during their new experience of motherhood. Teen mothers can be extremely vulnerable because of the many obstacles they may face including unhealthy relationships, lack of education attainment, mental health concerns, and isolation. One source of support can come from human service workers. In an effort to better understand the obstacles faced by teen mothers, and thus the obstacles faced by home visitors, this study focused on the stories, opinions, and experiences of those who are working with teen mothers in a home visiting setting. Participants’ interviews were analyzed for common struggles amongst the workers and teen mothers. Recommendations for improving practice strategies and policy are included

Images and Models of Thought

One really extraordinary ability of the mind is its capacity to match objects and form plausible hypotheses from just a few elements that we see through our eyes. We recognize a feather even if it is mostly covered by a book sitting on top of it. Even if we cannot see the whole shape, we recognize it as pertaining to a category, a set of objects called “feathers”. If by imagination we mean the ability to represent things for ourselves that are not present in the act of sensing, we should realize that the hypothesis of the feather is an imaginative construction of the mind, a mental representation, a model referred to by the sensory input

The History of the Dance Cards of Gettysburg College

The annual dances at Gettysburg College were the most popular social activity for students for over fifty years. The dance cards held in Special Collections at Musselman Library sparked an interest in the history of these dances and why they are not continued today. This research project uncovers the reason for the sudden extinction of a social event once adored by college students. It includes the prevalence of Greek life on campus and its effect on social life

Differential Tannakian Categories

We define a differential Tannakian category and show that under a natural assumption it has a fibre functor. If in addition this category is neutral, that is, the target category for the fibre functor are finite dimensional vector spaces over the base field, then it is equivalent to the category of representations of a (pro-)linear differential algebraic group. Our treatment of the problem is via differential Hopf algebras and Deligne's fibre functor construction.Comment: 24 pages; better structured Definition 2 and other statements of the paper; more examples; more detailed proof of Theorem 1

Maximum likelihood estimation of closed queueing network demands from queue length data

We propose maximum likelihood (ML) estimators for service demands in closed queueing networks with load-independent and load-dependent stations. Our ML estimators are expressed in implicit form and require only to compute mean queue lengths and marginal queue length probabilities from an empirical dataset. Further, in the load-independent case, we provide an explicit approximate formula for the ML estimator together with confidence intervals

Two new <i>Typhloreicheia</i> species from Sardinia and their biogeographical significance (<i>Coleoptera</i>, <i>Carabidae</i>,<i> Scaritinae</i>)

Typhloreicheia monacha sp. n. and T. ilianae sp. n. are described from two caves of Central-Eastern Sardinia (Nuoro province): the Bue Marino cave and the Nurra ‘e Pradu cave, respectively. Both caves are located in the part of the island where many highly specialised subterranean carabid beetles are localised. T. monacha is apparently related to two other species of the same area, i.e. T. onnisi Casale &amp; Magrini, 2004 and T. elegans (Dodero, 1916); T. ilianae is closely related to T. henroti Jeannel, 1957, known from a cave near Dorgali. Relationships and diagnostic features among these taxa are discussed and illustrated, and a key for identification of the specialised subterranean Typhloreicheia species of Sardinia is provided. The hypothesis of adaptive radiation of Reicheiina species in Sardinia, recently proposed by the senior author of this contribution, is further elaborated in light of new data