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Jennifer Cotto, et al. v. Andrea J. Campbell, Attorney General of Massachusetts, et al.

Paid petition · United States Court of Appeals for the First Circuit, No. 23-2069 · judgment January 21, 2025


Certiorari denied · January 12, 2026
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

Whether the unlawful retention of property by state officials—in this case, property forfeited from thousands of legally innocent persons whose wrongful state drug convictions have been vacated—is, as the First Circuit found, a “past wrong and not an ongoing violation for Ex parte Young purposes,” Cotto v. Campbell, 126 F.4th 761, 769 (1st Cir. 2025), or “part of an ongoing [constitutional] tort,” Maron v. Chief Financial Officer of Florida, 136 F.4th 1322, 1333-34 (11th Cir. 2025), as held by at least the Second, Fourth, Fifth, Sixth, Ninth, Tenth, and Eleventh Circuits.

Counsel of record

For petitioner
Daniel Nathan Marx
Fick & Marx LLP

For respondent
Christine Marie Fimognari
Massachusetts Office of the Attorney General

Case

Conference history
Distributed for 2 conferences

Linked docket
24A976

Proceedings

  1. Jan 12 2026
    Petition DENIED.
  2. Dec 10 2025
    DISTRIBUTED for Conference of 1/9/2026.
  3. Dec 05 2025
    Reply of petitioners Jennifer Cotto, et al. filed.
  4. Nov 24 2025
    Brief of respondents Andrea J. Campbell, et al. in opposition filed.
  5. Nov 05 2025
    Motion to extend the time to file a response is granted and the time is further extended to and including November 24, 2025.
  6. Nov 04 2025
    Motion to extend the time to file a response from November 10, 2025 to November 24, 2025, submitted to The Clerk.
  7. Aug 27 2025
    Motion to extend the time to file a response is granted and the time is extended to and including November 10, 2025.
  8. Aug 25 2025
    Motion to extend the time to file a response from September 10, 2025 to November 10, 2025, submitted to The Clerk.
  9. Aug 11 2025
    Response Requested. (Due September 10, 2025)
  10. Jul 16 2025
    DISTRIBUTED for Conference of 9/29/2025.
  11. Jul 10 2025
    Waiver of right of respondent Andrea J. Campbell, et al. to respond filed.
  12. Jun 18 2025
    Petition for a writ of certiorari filed. (Response due July 24, 2025)
  13. Apr 14 2025
    Application (24A976) granted by Justice Jackson extending the time to file until June 20, 2025.
  14. Apr 09 2025
    Application (24A976) to extend the time to file a petition for a writ of certiorari from April 21, 2025 to June 20, 2025, submitted to Justice Jackson.