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In another case involving the Racial Justice Act (see Montgomery above and Avalos below), the court issued an order to show cause, returnable in the superior court, in In re Naddi , a pro per’s habeas corpus petition. The Supreme Court directed the appellate court to issue an alternative writ.
Biden appointed the most judges to the Second Circuit in 2021, to the Ninth in 2022, and even had one judge begin active service in 2025 ( Embry Kidd in the Eleventh Circuit). The issue was whether federal courts can award equitable relief when state law permits it, but an adequate legal remedy exists. 5 Tangreti v.
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