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Writing
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Tom C. Clark Moot Court Competition
Tom C. Clark Moot Court Competition
This writing sample is the “Best Brief” of the 2024 Tom C. Clark Moot Court Competition at Suffolk University Law School. The competition’s case mimicked lots of the record from Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024), but the questions presented required us to analyze the Chevron and Major Questions Doctrine. I wrote all of the brief except the Major Question argument section.
My partner and I also won second place as Finalists in the oral argument section of the competition, where we won all but our last round. Neither of us had taken administrative law, and we were the only team not to be on Law Review or a secondary journal.
The brief follows the Bluebook for citation and standard margins; otherwise, we followed the Office of the Solicitor General Style Manual.
Clark Brief Final.pdf
This writing sample is an appellee brief for a vandalism case involving a long-standing neighborhood dispute in South Boston. In Massachusetts, vandalism is a mere codification of common law malicious mischief—requiring malice. During the trial, the judge said “or” instead of “and” in a malice instruction. The judge also allowed questions by the prosecution initially limited by the defendant’s motion in limine under the theory of curative admissibility.
The defendant brought an appeal from a denial of a new trial motion on four grounds:
(1) insufficient evidence,
(2) jury instruction error,
(3) ineffective counsel, and
(4) curative admissibility.
We prevailed on all four issues, upholding the conviction.
The brief follows the MA Appellate Court rules and the MA SJC Citation Guide, similar to the Bluebook.
2023-P-0617_02_Appellee_Brief-2.pdf
Commonwealth vs. Luisy Depina
Commonwealth vs. Luisy Depina
Commonwealth vs. Nicholas A. Circiello, IV
Commonwealth vs. Nicholas A. Circiello, IV
Commonwealth vs. Alexander Lopez
Commonwealth vs. Alexander Lopez
Oppositions to New Trial Motions
Oppositions to New Trial Motions
In all three cases, the defendants claimed they were forced to make crucial decisions—such as invoking their right to a jury trial—with their eyes closed and hands tied.
Depina and Circiello claimed that the court and counsel forced them to make a crucial decision—admitting to sufficient facts and taking a continuance without a finding—without notice of faulty breathalyzers.
Lopez claimed that the court and his counsel forced him to make a crucial decision—admitting to sufficient facts and taking a continuance without a finding—without notice of his immigration consequences.
Depina Opp. to Mtn to New Trial WS.pdfLopez Pineda 1205CR1844 Op. Mtn. New Trial w Exhibits.pdfCirciello New Trial Mtn Op w: exhibits.pdfPage updated
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