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e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. v. Solimino, 501 U.S. 104, 108 (1991), "the courts may take it as given that Congress has legislated with an expectation that th
at two district courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction. Smith v. Husband. 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe v, Liberatore, 478 F. Supp. 2d 742 (ED. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth a
e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. v. Solimino, 501 U.S. 104, 108 (1991), "the courts may take it as given that Congress has legislated with an expectation that th
at two district courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction. Smith v. Husband. 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe v, Liberatore, 478 F. Supp. 2d 742 (ED. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth a
e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. v. Solimino, 501 U.S. 104, 108 (1991), "the courts may take it as given that Congress has legislated with an expectation that th
at two district courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction. Smith v. Husband. 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe v, Liberatore, 478 F. Supp. 2d 742 (ED. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth a
e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. v. Solimino, 501 U.S. 104, 108 (1991), "the courts may take it as given that Congress has legislated with an expectation that th
at two district courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction. Smith v. Husband. 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe v, Liberatore, 478 F. Supp. 2d 742 (ED. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth a
e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. v. Solimino, 501 U.S. 104, 108 (1991), "the courts may take it as given that Congress has legislated with an expectation that th
at two district courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction. Smith v. Husband. 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe v, Liberatore, 478 F. Supp. 2d 742 (ED. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth a
e of an antecedent criminal conviction. Given that "Congress is understood to legislate against a background of common-law adjudicatory principles," Astoria Fed. Say. & Loan Assn. Solimino 501 U.S. 104, 108 (1991), 'the courts may take it as given that Congress has legislated with an expectation that the pr
at two district courts have held that plaintiffs may pursue a § 2255 action even without a prior conviction, Smith I. Husband, 376 F. Supp. 2d 603 (E.D. Va. 2005); Doe I. Liberatore 478 F. Supp. 2d 742 (E.D. Pa. 2007). But with due respect, these decisions overlook the relevant legislative history set forth a
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