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| | writ of certiorari - definition of writ of certiorari in Encyclopedia |
 | | Certiorari is sometimes informally referred to as cert, and cases warranting the Supreme Court's attention as certworthy. | | | Historically, certiorari was a prerogative writ used to direct a lower court or tribunal to certify for review the "record" in the case. | | | In the federal courts, this use of certiorari has been abolished, and replaced by a civil action under the Administrative Procedure Act in a United States District Court, or in some circumstances, a petition for review in a United States Court of Appeals. |
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http://encyclopedia.laborlawtalk.com/writ_of_certiorari
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| | Certiorari |
| | Certiorari is ordinarily used to bring the record of a judicial or quasi-judicial body before a superior court in order to determine whether the inferior body acted within its jurisdiction and should be utilized where there is no other adequate remedy such as appeal. | | | In Missouri, the writ of certiorari is the same as at common law, and courts may properly adopt usages and principles applicable to the issuance of the writ as developed under the common law system, consistent with the letter and spirit of existing statutes and the constitution. | | | Ordinarily on a writ of certiorari, review is only of the validity of the lower court record, infirmities in jurisdiction and questions of the law; questions of fact or merits of the case are not reviewable. |
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http://www.mobar.org/handbook/certiorari.htm
(264 words)
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| | Duely and Constantly Kept |
| | The writ of certiorari was also used to remove judgments in justices' civil courts directly to the Supreme Court for review (bypassing the courts of common pleas and the mayors' courts). | | | Statute law also authorized use of writ of certiorari to transfer a pending criminal indictment in a court of oyer and terminer or (until 1830) court of general sessions to the Supreme Court, but only with permission of a Supreme Court justice. | | | Supreme Court review of civil cases from justice's courts was abolished by Laws of 1824, Chap. |
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http://www.courts.state.ny.us/history/elecbook/duely/pg21.htm
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| | "Certiorari" Defined |
| | Certiorari is the general method most cases make their way to be heard by the U.S. Supreme Court since it has specific jurisdiction over a very limited range of disputes. | | | This is the name of a writ issued from a superior court directed to one of inferior jurisdiction, commanding the latter to certify and return to the former the record in the particular case. | | | A certiorari, for example, is the correct process to remove the proceedings of a court of sessions or of county commissioners in laying out highways. |
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http://www.lectlaw.com/def/c024.htm
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| | Pamela F. SKOKOS v. Honorable Alice S. GRAY |
| | Certiorari does not lie to disqualify a judge from hearing a proceeding unless the judge is proceeding illegally, or in want, or in excess, of his or her jurisdiction. | | | Certiorari lies where there is a want of jurisdiction or an act in excess of jurisdiction which is apparent on the face of the record. | | | Certiorari, Writ of -- consideration of issue on petition precludes consideration on appeal -- matters at trial not precluded. |
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http://courts.state.ar.us/opinions/old/94-952A.html
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| | Bench & Bar of Minnesota |
| | Certiorari is an unusual process by which the attorney representing the claimant obtains the writ and serves it. | | | Since it is jurisdictional it cannot be extended by the court or by stipulation of the parties. | | | In English common law, certiorari review was a writ from a superior court to an inferior court requiring it to produce a record which the high court would review for "irregularities" -- by definition a limited scope of review. |
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http://www2.mnbar.org/benchandbar/2000/m-j00/wrongful-term.htm
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| | Definition: Certiorari, Petition for Writ of Certiorari. |
| | The abbreviation used in legal citations to indicate that the Supreme Court denied a Petition for Writ of Certiorari in the case being cited. | | | It is also the name given to certain appellate proceedings for re-examination of actions of a trial court, or inferior appeals court. | | | A petition for writ of certiorari will be granted only for compelling reasons." Rule 10, Rules of the U.S. Supreme Court. |
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http://www.techlawjournal.com/glossary/legal/certiorari.htm
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| | FindLaw - US Supreme Court Order - 04/04/2005 |
| | The petition for a writ of habeas corpus is denied. | | | The judgment is vacated and the case is remanded to the United States Court of Appeals for the Eleventh Circuit for further consideration in light of United States v. |
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http://supreme.lp.findlaw.com/supreme_court/orders/2004/040405pzor.html
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| | Petition for Writ of Certiorari by the State of Colorado |
| | Certiorari review is also necessary to correct the misapplication by the court of appeals of well settled law regarding appellate review of the sufficiency of the evidence. | | | Pursuant to C.A.R. 49, the People respectfully petition this court for a writ of certiorari. | | | On Certiorari to the Colorado Court of Appeals |
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http://www.levellers.org/jrp/csc.cert.htm
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| | globalink-certiorari-reply |
| | Whether this Court has jurisdiction to issue a writ of certiorari to the Supreme Court of Pennsylvania where the Petitioner has preserved a federal issue in the Pennsylvania state courts, and has raised federal issues in the petition. | | | Whether this Court has jurisdiction to issue a writ of certiorari to the Supreme Court of Pennsylvania where all the Pennsylvania state courts’ decisions did not rest on “adequate and independent” state law principles. | | | This Court has jurisdiction to issue a writ of certiorari to the Supreme Court of Pennsylvania, where the Petitioner has preserved a federal issue in the Pennsylvania state courts, and has raised federal issues in the petition. |
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http://sklaroff.globalink.org/globalink-certiorari-reply.html
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| | Dissenting Opinion by Davis, J., Scott v. Stewart, No. 29772 |
| | The decision in Falconer concerned filing a writ of certiorari instead of an appeal to the circuit court from a judgment from the justice of the peace court. | | | The writ of certiorari may only be used when no mechanism for review of a judicial or quasi-judicial proceeding is provided for by law. | | | State Road Comm'n, 103 W. Va. 714, 719-720, 138 S.E. 362, 364 (1927) (“The writ [of certiorari] is an extraordinary remedy resorted to for the purpose of supplying a defect of justice in cases obviously entitled to redress and yet unprovided for by the ordinary forms of procedure.”); Ashworth v. |
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http://www.state.wv.us/wvsca/docs/fall01/29772d.htm
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| | FindLaw Professionals: Petitioning and Opposing Certiorari in the U.S. Supreme Court |
| | The Supreme Court is not a court of error; it does not intervene simply to correct injustices and misapplications of the law. | | | Ideally, then, the certiorari petition will demonstrate both that the lower courts are in disarray on the issue the Supreme Court is being asked to review and that the issue is of considerable national importance. | | | See Bishop, Opposing Certiorari in the U.S. Supreme Court, Litigation 31, 32 (1994) (discussing the procedures surrounding waiver of the brief in opposition to certiorari). |
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http://profs.lp.findlaw.com/appellate/cert1.html
(2865 words)
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| | Petition for Certiorari |
| | The parties to the proceeding in the United States Court of Appeals for the District of Columbia are those in the caption. | | | PETITION FOR A WRIT OF CERTIORARI TO Petitioner herein respectfully prays that a writ of certiorari issue to review the judgement of the United States Court of Appeals for the District of Columbia entered on October 3, 1996. | | | Certiorari should be granted to consider whether the Final Order should be set aside because the decision was made without the procedure required by law. |
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http://www.druglibrary.org/olsen/dea/cert-pet.html
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| | Supreme Court of the United States - encyclopedia article about Supreme Court of the United States. |
| | If the Supreme Court grants the writ of certiorari (or the certified question or other extraordinary writ), then a briefing schedule is arranged for the parties to submit their briefs in favor of or against a particular form of relief. | | | During this time, an individual or group that has an interest in a case but is not a party to the case can submit a motion to appear before the court as amicus curiæ ("friend of the court"). | | | If the Court refuses to grant certiorari, it does not comment on the merits of the case; the decision of the lower court stands unchanged as if Supreme Court review had not been requested. |
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http://encyclopedia.thefreedictionary.com/Supreme+Court+of+the+United+States
(7871 words)
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| | Hon. Peter J. Messitte, "The Writ of Certiorari: Deciding Which Cases to Review " , eJournal USA: Issues of Democracy, ... |
| | The act authorized use of the writ of certiorari (or "cert", from the Latin "to be informed"), by which the Court directs an inferior court to certify and transmit for review the record of a particular case. | | | Any party to a litigation who feels aggrieved by a final judgment of a federal Court of Appeals or by the highest state court, in any civil or criminal case, may file a petition with the Supreme Court. | | | The respondent may, but is not required to, file a brief opposing the petition, arguing that the Court should not grant certiorari, and the petitioner is permitted to file a response to that reply brief. |
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http://usinfo.state.gov/journals/itdhr/0405/ijde/messitte.htm
(2420 words)
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| | Certiorari - Wex |
| | Originally, the writ of certiorari was a proceeding through which a superior court required a lower court to submit the full record of a case for review. | | | Rule 10 (http://www.law.cornell.edu/rules/supct/10.html) of the Supreme Court Rules lists some of the considerations that may lead the Court to grant certiorari. | | | In Arizona, for example, relief formerly obtained by the writs of prohibition, mandamus and certiorari is now obtained through a "special action." |
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http://www.law.cornell.edu/lexicon/certiorari.html
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| | Petition for Certiorari, U.S. Supreme Court, Case No. 01-249 |
| | The petitioner, therefore, urges this Honorable Court to grant a writ of certiorari to correct the error of the lower court and to resolve the conflict of law that exists in the circuit courts. | | | The present Petition for Writ of Certiorari is filed within 90 days of the denial of Petition for Panel Rehearing by the Fifth Circuit and is timely pursuant to 28 U.S.C. §§1257 and 2101(c) and Rule 10(1)(c) of the Rules for the U.S. Supreme Court. | | | Further, the decision of the Fifth Circuit Court of Appeals conflicts with the decisions of the Third and Ninth Circuit Courts of Appeals on the issue of whether a negative job reference by an ex-employer is an adverse employment action in a retaliation claim under Title VII. |
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http://www.tulanelink.com/legal/supreme_01a.htm
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| | No. 04-1084: Gonzales v. O Centro - Petition |
| | The decision of the court of appeals enjoins the federal government from enforcing a longstanding and unquestionably constitutional criminal law that bans the importation, possession, distribution, and use of a Schedule I controlled substance. | | | This Court denied the government's motion to stay the injunction pending the filing of a petition for a writ of certiorari. | | | The petition for a writ of certiorari should be granted. |
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http://www.usdoj.gov/osg/briefs/2004/2pet/7pet/2004-1084.pet.aa.html
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| | Microsoft PressPass - Microsoft's Petition for Certiorari |
| | The States also petitioned this Court for a writ of certiorari in their case. | | | PETITION FOR A WRIT OF CERTIORARI TO Petitioner Microsoft Corporation respectfully petitions for a writ of certiorari to review the judgment of the United States Court of Appeals for the District of Columbia Circuit. | | | This Court declined to hear the appeal of the DOJ’s case and denied the States’ petition for a writ of certiorari. |
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http://cyber.law.harvard.edu/msdoj/010807cert.html
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| | FOIA Update: Certiorari Granted |
| | In seeking certiorari, the Department of Justice contended to the Supreme Court that the court of appeals' "construction of Exemption 6 finds no support in the exemption's language or legislative history, defeats its underlying purpose and cannot be reconciled with this Court's explanation of the exemption in Department of the Air Force v. | | | The Court has also granted certiorari in Abramson v. | | | The Shapiro case was scheduled for oral argument on Dec. 2; no argument date has yet been set for either Abramson or Washington Post. |
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http://www.usdoj.gov/oip/foia_updates/Vol_III_1/page6.htm
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| | 246 Pa. Code Rule 1009. Praecipe for Writ of Certiorari. |
| | Under subdivision B, the praecipe for the writ of certiorari must be filed within thirty days after the date of the judgment, except when a question of jurisdiction is raised. | | | D. The praecipe and the writ shall be on a form which shall be prescribed by the State Court Administrator. | | | If the party aggrieved by the judgment was the plaintiff in the action before the magisterial district judge, he may file a praecipe for a writ of certiorari only on the last mentioned ground. |
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http://www.pacode.com/secure/data/246/chapter1000/s1009.html
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| | Opposition to Certiorari |
| | The Nussbeck case involved imprisonment for failure to pay maintenance and child support and was relied on by the Court of Appeals in finding that a finding of contempt for violation of a court order does not subject a parent to imprisonment for failure to pay a debt. | | | The granting of a petition for certiorari is purely discretionary with the court and should be granted only where there are “special and important” reasons therefor. | | | On Certiorari to the Colorado Court of Appeals |
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http://www.childrensjustice.org/litigation/Litigation/StillmanvCO/COSupremeCourt/opposition_to_certiorari.html
(1796 words)
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| | [No title] |
| | PETITION FOR WRIT OF (50) CERTIORARI TO THE COURT OF CIVIL APPEALS (In re: Greenbriar Village, L.L.C. v. | | | PETITION FOR WRIT OF CERTIORARI TO THE COURT OF CIVIL APPEALS (In re: Tolsa R. Travis-Johnson v Keith Elliott Johnson) (Macon Circuit Court: DR-97-10.01; Civil Appeals : 2010110). | | | Writ Denied - No Opinion 1011913 Ex parte Greenbriar Village, L.L.C. (50) CERTIORARI TO THE COURT OF CIVIL APPEALS (In re: Greenbriar Village, L.L.C. v. |
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http://www.wallacejordan.com/decisions/Opinions2002/as121302.txt
(4139 words)
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| | Petition for Writ of Certiorari |
| | This Court should grant certiorari for three reasons: the decision below conflicts with decisions of this and other Courts; these conflicts result in part from uncertainties in this Court's jurisprudence; and this is a case of exceptional importance. | | | 8 Moreover, certiorari to the United States Supreme Court was not sought in any of the cited cases, and it appears that Court has never addressed this issue. | | | For the foregoing reasons, the petition for writ of certiorari should be granted. |
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http://www.cfarfreedom.org/brief_white.shtml
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| | Erowid Psilocybin Mushroom Vault : Law : Writ of Certiorari to Federal Supreme Court : Iowa V Atley |
| | This Court should grant certiorari due to the National Importance, in that the interpretation of "material" to encompass non-specified plants would permit "a standardless sweep" and open up almost every citizen to arrest and imprisonment by giving unbridled license to law enforcement to "pursue their personal predilection" of arbitrary and discriminatory enforcement. | | | The statute, as presently framed, without this Court's determination as to the scope of the term "material," not only fails to accomplish the legislative goals, under the Iowa Supreme Court's Opinion, it is a threat to the right to Due Process and to the protections afforded by the Constitution. | | | This Court should grant certiorari to consider whether Petitioner's cultivation of mushrooms is no more prohibited than if he cultivated Morning Glories, sensitive plants, or any plant or organism not specified, regardless of his "knowledge" that they contain a controlled substance. |
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http://www.erowid.org/plants/mushrooms/mushrooms_law6.shtml
(10510 words)
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| | Pro Se Guide: Procedures for Filing Petition for Writ of Certiorari |
| | Petition For Writ Of Certiorari Filed -The Petition is due 30 days after the entry of the final decision by the Court of Appeals. | | | They can be used as a general guideline as to the manner in which a writ is constructed, but keep in mind that the information in these petitions is directed strictly to a specific appeal and may not have any bearing at all on your case. | | | This includes ordering you to pay a fine to the court or pay the legal fees of the person or persons against whom you filed the writ. |
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http://www.utcourts.gov/resources/forms/certi/prose.htm
(1535 words)
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| | Certiorari |
| | The Latin term "Certiorari" means, in a UK legal context: "a writ from a High Court to a lower Court." |
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http://www.clickdocs.co.uk/glossary/certiorari.htm
(37 words)
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| | PETITION FOR WRIT OF CERTIORARI |
| | This Honorable Court should grant certiorari and either grant a full hearing hereon or in the alternative, find that this case is ripe for disposition and grant a summary reversal. | | | This Honorable Court should grant Certiorari, reverse the dismissal of the Complaint and allow a trial on the merits. | | | The Government’s attempt to circumvent the lawful payments to the relator in qui tam cases has caused considerable litigation by relators who discover that they were not paid for the benefits and proceeds repaid to the Government and the agencies involved. |
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http://www.ballew.com/bob/htm/writ01.htm
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| | Supreme Court Grants Certiorari in Patent Tying Antitrust Case, 6/20/2005. |
| | The American Bar Association filed an amicus brief [PDF] urging the Supreme Court to grant certiorari, and reverse the Court of Appeals. | | | Supreme Court Grants Certiorari in Patent Tying Antitrust Case, 6/20/2005. | | | Supreme Court Grants Certiorari in Patent Tying Antitrust Case |
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http://www.techlawjournal.com/topstories/2005/20050620.asp
(360 words)
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| | FindLaw for Legal Professionals - Case Law, Federal and State Resources, Forms, and Code |
| | Note: Certiorari is one of the two ways to have a case from a U.S. Court of Appeals reviewed by the U.S. Supreme Court. | | | Certiorari is also used within state court systems. | | | Find a Lawyer: Our free service locates Bankruptcy, Criminal, DUI, Family, Immigration, Personal Injury, Real Estate, or Trademark lawyers in your area who can help you with your legal issues. |
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http://dictionary.lp.findlaw.com/scripts/results.pl?co=www.findlaw.com&topic=77/7743f0116b805ec5a9f77f320794fca4
(316 words)
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| | U.S. Supreme Court Monitor - Certiorari Granted |
| | Links from the case names provide information about when certiorari was granted, lower court case history, counsel and amicus filings. | | | This section contains all cases in which the United States Supreme Court has granted certiorari, both scheduled arguments and unscheduled cases. | | | To view a case in which the Court has already issued an opinion please search the Full-text Decisions section. |
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http://www.law.com/jsp/scm/cur.jsp
(60 words)
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| | Gratz--Conditional Opposition to Certiorari |
| | certiorari to review a case pending in a United States court of | | | certiorari before judgment in the court of appeals, which this | | | be possible if the Court granted certiorari in only one case. |
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http://www.umich.edu/~urel/admissions/legal/gratz/gra-copcert.html
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| | Petition for Certiorari |
| | Because the decision of the court of appeals in this case fails to recognize an individual's paramount right to keep private her most personal information, this Court should grant certiorari and overturn the court of appeals' ruling or remand it for reconsideration in light of this Court's holding in Reno v. | | | For the reasons set forth above, amici EPIC and the AARP respectfully urge the Court to grant certiorari and reverse the decision of the court of appeals, or alternatively to remand in light of Reno v. | | | What is most important is that this Court did not find an opt-in approach overly restrictive or, as the court of appeals held with respect to CPNI, that the DPPA had to employ the least restrictive means of achieving its end. |
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http://www.epic.org/privacy/litigation/USWest/cert_pet.html
(3665 words)
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| | Conditional Opposition to Certiorari -- Gratz |
| | Assuming this Court denies the petitions for certiorari in | | | petition for a writ of certiorari to review a case pending in a | | | CERTIORARI IN As stated in the Conditional Opposition in Gratz, if this |
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http://www.umich.edu/~urel/admissions/legal/gratz/gra-iopcert.html
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| | Petition for Certiorari in Eldred v. Ashcroft |
| | This Court Should Grant Certiorari To Resolve a Conflict in the Circuits About The Relationship Between Congress’ Copyright Power And The Restrictions of The First Amendment. | | | I. This Court Should Grant Certiorari To Resolve A Conflict in the circuits About The Limits On Congress’ Power Under The Copyright And Patent Clause. | | | This case provides the Court with an opportunity to resolve both dimensions of this confusion in authority. |
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http://cyber.law.harvard.edu/openlaw/eldredvashcroft/cert-petition.html
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| | EFF: MGM v. Grokster |
| | Relying on the Betamax precedent, the court ruled that the distributors of Grokster and Morpheus software cannot be held liable for users' copyright violations. | | | EFF's Brief in Opposition [PDF 343k] of Petition for certiorari. | | | Washington Law Foundation's Brief in Support [PDF 1.1M] of certiorari. |
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http://www.eff.org/IP/P2P/MGM_v_Grokster
(1845 words)
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| | Washington Supreme Ct.Certiorari |
| | The Court grants certiorari only “where there are special and important reasons therefor.” This amount to 10 to 15 percent of the certiorari petitions received in a given year. | | | Rarely does an individual bring more than one certiorari issue to the Court. | | | Ninety percent of the cases decided annually by the Supreme Court started as a writ of certiorari. |
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http://peopleslobby.hypermart.net/alaskanlightnigboltssupremecourt7196.htm
(491 words)
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| | Information on Filing Petition for Writ of Certiorari |
| | A petition for writ of certiorari filed in the Court of Appeals seeking review of a decision of the Court of Special Appeals is to be filed no later than 15 days from the date of the mandate of the Court of Special Appeals. | | | A petition seeking review of a circuit court decision on appeal from the District Court of Maryland is to be filed 30 days from the date of the judgment of the circuit court. | | | Information on Filing Petition for Writ of Certiorari |
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http://www.courts.state.md.us/coappeals/cert-petitions.html
(245 words)
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| | Petition for Certiorari, Pletten v Horner, # 89-7594 |
| | This matter is before the court upon consideration of the appellant's petition for rehearing of the court's December 14, 1989 opinion affirming the decision of the district court. | | | For these reasons, I respectfully request that this Court grant certiorari, adjudicate controlling issues, and remand for administrative review to begin. | | | This case presents issues of enforcement, due process, court jurisdiction, secret law, job qualifications, freedom of expression, premature judicial decision usurping administrative review, impartiality, and spurious findings of fact. |
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http://medicolegal.tripod.com/starcertret.htm
(10685 words)
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| | globalink-certiorari |
| | Petitioner Robert B. Sklaroff, MD, respectfully petitions for a Writ of Certiorari to review the judgment of the Pennsylvania Supreme Court in this case. | | | “Final judgments or decrees rendered by the highest court of a State in which a decision could be had, may be reviewed by the Supreme Court by writ of certiorari. | | | The opinion and order of the Court of Common Pleas (First Judicial District of Pennsylvania) was issued on February 26, 1999 [Appendix A]. |
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http://sklaroff.globalink.org/globalink-certiorari.html
(9117 words)
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| | EFF: Breaking News |
| | The Court will hear oral arguments in the case in March 2005. | | | Since June 2004, Omidyar Network has funded efforts in a number of areas: microfinance, bottom-up media, open source, intellectual property, and electronic voting. | | | The US Supreme Court today granted certiorari in MGM v. |
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http://www.eff.org/news/archives/2004_12.php
(691 words)
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| | U S Supreme Court PETITION FOR WRIT OF CERTIORARI - IN RE FRANK R. BONCZYK |
| | Petition for Writ of Certiorari to Constitutionally define statutory category of patentable subject matter under 35 U.S.C. Viable and Non-viable definitions applied to primary life structure[s] (fetus) by the court are vague and place discretionary power in the hands of physicians | | | U S Supreme Court PETITION FOR WRIT OF CERTIORARI - IN RE FRANK R. No. 01 - 262 | | | Because the Board's decision is correct as a matter of law, we affirm. |
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http://www.nitorig.net/ussa_writ1.htm
(1015 words)
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| | [No title] |
| | By denying such a writ the Supreme Court says it will let the lower court decision stand, particularly if it conforms to accepted precedents (previously decided cases). | | | Certiorari is most commonly used by the U.S. Supreme Court, which is selective about which cases it will hear on appeal. | | | To appeal to the Supreme Court one applies to the Supreme Court for a writ of certiorari, which it grants at its discretion and only when at least three members believe that the case involves a sufficiently significant federal question in the public interest. |
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http://dictionary.law.com/definition2.asp?selected=164&bold=
(124 words)
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| | Petitions for Certiorari, Dennis P. Derrick Attorney at Law |
| | A Practice Dedicated Solely to the Preparation of Petitions for Certiorari, Main Briefs and Amicus Curiae Briefs in the United States Supreme Court as well as Appellate Briefs in both State (Massachusetts) and Federal courts. | | | Petitions for Certiorari, Dennis P. Derrick Attorney at Law | | | Click here to see the site terms of use. |
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http://www.certworthy.com
(100 words)
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| | PETITION FOR A WRIT OF CERTIORARI |
| | Petitioner Mumia Abu-Jamal prays that a writ of certiorari issue to review the judgment of the Supreme Court of Pennsylvania in this case. | | | The opinion of the Supreme Court of Pennsylvania on appeal is reported at Commonwealth v. |
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http://www.refuseandresist.org/mumia/1999/043099SCBRIEF.html
(6181 words)
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| | TaxProf Blog: Supreme Court Grants Certiorari in Cuno v. DaimlerChrysler |
| | Listed below are links to weblogs that reference Supreme Court Grants Certiorari in Cuno v. | | | TaxProf Blog: Supreme Court Grants Certiorari in Cuno v. | | | The Supreme Court announced today that it has granted certiorari in Cuno v. |
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http://taxprof.typepad.com/taxprof_blog/2005/09/supreme_court_g.html
(767 words)
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| | LW2: Certiorari Memorandum |
| | Be prepared to discuss whether you would vote to grant or deny the petition for certiorari. | | | You are to assume you are a justice on the Supreme Court of the United States and Gov. Bush's certiorari petition is to be taken up at the Court's weekly status conference. | | | You may find it helpful also to review the relevant Florida Supreme Court opinion. |
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http://www.law.howard.edu/faculty/pages/berry/lw2/spring2003/certmemo.htm
(132 words)
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