Legal review · Links checked : the source is available · Scope & methodology
This record is not a citator check. Confirm later history and treatment before relying on it.
authority type
case
jurisdiction
federal_first_circuit
publication status
published_precedential_opinion
precedential status
binding_in_ca1
decision or issuance date
1991-06-10
subsequent history
Bounded public-source treatment review completed through 2026-08-26; no explicit adverse treatment located.
negative treatment status
No explicit adverse treatment located in a bounded public-source review through 2026-08-26; comprehensive commercial citator not run.
material limitations
Published precedential full opinion reviewed from a public reporter reproduction after no stable historical official opinion file was located. Holder expressly left survival of the writ unresolved, rejected a pure-equity immigration-consequence theory, and identified no actual gap. A 2021 official First Circuit published opinion continued to cite Holder without adverse treatment.
Assuming audita querela survives in federal criminal cases, it requires a legal objection arising after conviction that is not redressable through another postconviction remedy; purely equitable consequences are insufficient.
Material limitation
Binding only in the First Circuit and only for the bounded procedural postures in the linked claims. Published precedential full opinion reviewed from a public reporter reproduction after no stable historical official opinion file was located. Holder expressly left survival of the writ unresolved, rejected a pure-equity immigration-consequence theory, and identified no actual gap. A 2021 official First Circuit published opinion continued to cite Holder without adverse treatment. A comprehensive commercial citator was not run.