This writing sample consists of excerpts from an opening brief filed in the United States Court of Appeals for the Sixth Circuit. I prepared the brief as a student intern at the UCLA School of Law Prisoners’ Rights Clinic on behalf of a state prisoner whose pro se civil rights complaint was dismissed with prejudice at the screening stage under 28 U.S.C. § 1915A of the Prison Litigation Reform Act.

I conducted the research and drafted the sections included herein, and my supervising clinic professor has authorized this submission. This is the submission after input and revision from colleagues.

On October 17, 2025, the Sixth Circuit decided Mr. Bass’s appeal, and we won! Although the court did not agree with us that Mr. Bass’s pro se complaint sufficiently stated an Eighth Amendment claim, it held that the district court abused its discretion in dismissing Mr. Bass’s complaint with prejudice and without leave to amend with respect to both the First and Eighth Amendment claims. The opinion also includes helpful language about which allegations would suffice to state both claims, and in that discussion, it’s clear the court took our arguments seriously about what Mr. Bass could include in an amended complaint. For example, on page eight of the opinion, the court wrote:

More fulsome allegations regarding the concrete slab and Bass’s sleeping conditions

could likely be alleged in an amended complaint. And if an amended complaint were to include

allegations that Bass was indeed subjected to a sufficiently serious risk of grievous injury due to

the “concrete slab with metal screws” upon which he was forced to sleep, such allegations would

likely be sufficient to plausibly plead an Eighth Amendment claim.

This writing sample is a petition I drafted as a student intern at Nova Southeastern University’s Disability Inclusion and Advocacy Law Clinic on behalf of a pro bono client. The petition argues that the Petitioner, notwithstanding a prior criminal conviction, is qualified to serve as guardian advocate for her minor son with a disability under Florida’s guardian advocate statute.

Some identifying information has been redacted to preserve client confidentiality. My supervising clinic professor has authorized this submission. I conducted the research and drafted the petition, and the work has not been substantially revised by others. It reflects the quality of my independent legal research and writing.

 As a Summer Fellow at Yale Law School’s Jerome N. Frank Legal Services Organization, I

conducted research on federal resentencing, specifically focusing on the compassionate release

landscape under the First Step Act (FSA). The purpose of this research was to inform the Criminal Justice Clinic’s pro bono representation strategy and to guide decisions on which cases to pursue.

My supervising attorney has authorized the submission of this memo as a sample of my legal and policy research and writing, and I believe it reflects the quality of my work. It has not been substantially edited by anyone else.