Litigation Writing

As a student in the UCLA School of Law Prisoners' Rights Clinic, I helped brief this Sixth Circuit appeal for a state prisoner whose pro se civil-rights complaint was dismissed with prejudice at screening under 28 U.S.C. § 1915A. This sample is the portion I drafted—the Statement of the Case, the Standards of Review, and the fact-driven core of the leave-to-amend argument: that denying Mr. Bass a chance to amend without explanation was an abuse of discretion, and that the defects the court identified were curable with facts he could plead.

The Sixth Circuit agreed, vacating the dismissal and remanding with instructions to allow amendment. I revised the excerpt in July 2026; those revisions are mine alone. The full filed brief and the decision appear below.

The complete opening brief filed in the Sixth Circuit—my clinic team's case, carried from inception to filing with the Roderick & Solange MacArthur Justice Center as co-counsel. The UCLA Prisoners' Rights Clinic briefs three appeals each semester; this was ours. It is a collective work, credited to clinic students Binwant Kaur Kahlon, Mark Pampanin, Shannon Saul, and me, with guidance from our supervising professors, the faculty director, and the clinic's law librarian, and input from Mr. Bass. I include it so the finished, filed product sits alongside the portion I drafted in Sample 1.

On October 17, 2025, the Sixth Circuit ruled in our favor. The court reversed the dismissal of Mr. Bass's complaint and remanded with leave to amend his First and Eighth Amendment claims—on the abuse-of-discretion argument I drafted: the defects the district court identified were curable, and the answer to a thin pro se complaint is leave to amend, not dismissal with prejudice.

The court did not hold that the original complaint already stated an Eighth Amendment claim, but that was never the path that mattered. By setting out the facts Mr. Bass could plead, we showed amendment would not be futile—the one thing that could have justified denying him leave to replead. The panel's instructions for the amended complaint tracked our brief:

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. Mr. Bass now has the chance to replead the claims he never should have lost.

This writing sample is my draft of a memorandum of law supporting a first petition for a writ of habeas corpus under 28 U.S.C. § 2254, prepared for a client at the Jeffrey Deskovic Foundation for Justice and filed in the United States District Court for the Northern District of New York.

The client is serving life without parole on a conviction built entirely on circumstantial evidence—no eyewitness, no confession, no physical evidence. The memorandum argues that newly discovered evidence clears the Schlup gateway and shows the trial evidence was legally insufficient, and that trial counsel was ineffective for failing to investigate the prosecution's cell-tower evidence and to interview a key witness—failures appellate counsel never raised. My supervising attorney reviewed the draft and made limited edits before filing; the version posted here is my own work, informed by that feedback.

One adaptation: this version presents the new-evidence showing as a Schlup gateway to keep the sample self-contained; in the case as filed, the gateway had already been established, and the petition proceeded directly to the merits.

As a Summer Fellow at Yale Law School's Jerome N. Frank Legal Services Organization in 2025, I surveyed three years of federal compassionate-release decisions under the First Step Act. The Criminal Justice Clinic used the research to shape its pro bono strategy and to choose cases. I drafted the memo; it is my own work, and my supervising attorney authorized this submission.

I updated it to address the Supreme Court's decisions in Fernandez v. United States and Rutherford v. United States.

Almost no one is convicted at trial anymore. Guilty pleas resolved 98% of federal criminal convictions in 2025—and about one in four of the 3,842 exonerations recorded since 1989 involved an innocent person who pleaded guilty to a crime he did not commit–without the help of DNA.

This article examines how coercive plea bargaining produces those wrongful convictions. It traces six recurring pressures—false confession, perjury, official misconduct, faulty forensics, inadequate defense, and mistaken identification—through the cases of six innocent men who pleaded guilty without any DNA evidence to clear them. It then follows plea bargaining from its nineteenth-century origins to Brady v. United States, where the Supreme Court sustained the practice on the promise that judges could separate voluntary pleas from coerced ones, and vowed to revisit that holding if innocent people began pleading guilty in significant numbers.

That number has long since been reached. Weighing the ABA's 2023 Plea Bargain Task Force Report against its critics, the article proposes a reform from within—dividing the prosecutor's charging, plea, and trial functions—so the system can no longer convict the innocent by agreement.

Bail reform promised to stop jailing people for being poor. Drawing on eight years of New Jersey data—more than 300,000 warrant charges and nearly 60,000 detention orders—this paper argues that the state's flagship reform traded one injustice for another. For noncapital offenses that historically carried a guaranteed right to bail, the law now presumes detention on a bare probable-cause finding—even when the state's own algorithm scores the arrestee at its lowest risk levels. The paper makes the case for revisiting United States v. Salerno and proposes statutory fixes to restore the presumption of innocence and prevent punishment before conviction.