TEACHING SPECIMENS
Four Federal Dockets
These cases were not discretionary filings. They arose because distinct institutional failures could not be addressed within a single proceeding. Each demonstrates the Hayes Canon methods in real federal court conditions.
1:25-cv-12208
D. Mass.
Status: Structurally void, procedurally frozen
Defendant: Eastern Bank (~$25B assets)
Origin: ~$33K liquidity dispute
Eastern Bank / Removal / Enforceability
The entry point was banal on its face: a private bank, a small liquidity dispute, a loan derived from earlier fraudulent instruments. But the response was wildly disproportionate—full litigation machinery deployed against someone with no assets in their name, no lien ever lawfully pursued.
The decisive question emerged: By what mechanism does the court actually compel outcome?
The answer is: it doesn't. The court assumes enforcement without possessing it. That is not authority. That is theater.
What the record proves:
- → Removal under §1446(d) was never lawfully reconciled
- → Custody fractured: state court continued post-removal
- → Federal court issued unsigned, non-adjudicative actions
- → No court has ever ruled on the Notice of Removal itself
- → Silence replaced adjudication
This case demonstrates how custody, jurisdiction, and enforceability collapse under modern docket systems.
1:25-cv-12881
D. Mass.
Status: Live, mischaracterized in form
Defendants: Mayor Wu, AG Campbell, City Council
Type: Quo Warranto / Civil Rights
Quo Warranto / Civil Rights
Initiated to test adjudicability where procedure had displaced substance. Structural failures tied to access, parity, and administrative non-response following removal.
The docket was mislabeled as FCA when it is a civil-rights / Quo Warranto action. That mislabeling itself constitutes structural distortion. The court avoided correction until recent silent alteration.
Current posture:
- → Every party is in active Rule 55(a) default
- → AG has a structurally impossible dismissal motion pending
- → CM/ECF handling creates access friction
- → That friction generated evidence, not damage
This case demonstrates how classification errors become rights violations.
1:25-cv-13582
D. Mass.
Status: Substantively strong, procedurally slow
Defendants: Triton, Committee, Superintendent, DESE
Type: Education / Civil Rights / Retaliation
Triton / Education / Retaliation
Origin: unresolved constitutional and retaliatory injury predating the bank dispute. Purpose: test adjudicability in a civil-rights context where harm was already established and documented, not speculative, and where intent was dispositive.
Because of the unclean handling of the matters previous, this fourth, clean matter was brought to the court to provide a control case.
What the record shows:
- → Factual record is simple, documented, emotionally restrained
- → Retaliation and speech suppression are unrebutted
- → Default mechanics and response asymmetries are visible
- → Delay without engagement strengthens remedies
Where abstract structure meets lived consequence.
False Claims Act
Derived from 12208
Status: Latent leverage
Type: FCA / SBA Regulatory Fraud
The FCA Hinge
Eastern Bank's enforcement action necessarily presupposes a federally valid SBA-guaranteed instrument. That presupposition is false. Everything that follows—state-court enforcement, federal removal resistance, lien pursuit, and retaliation—depends on a guarantee that appears never to have lawfully existed.
The False Claim
Based on the public record in 12208, Eastern Bank's conduct implies representations that loan instruments were SBA-compliant, the guarantee stack was valid, and federal underwriting prerequisites were satisfied.
Yet the record shows:
- → Missing or unproducible SBA forms (147, 148, 149, 159, 1919, 1920)
- → Conflicting signature pages
- → A 2014 signature page tied to a 2016 transaction
- → No evidence of SBA recertification during later restructuring
- → No proof that SBA ever approved, reapproved, or reaffirmed any guarantee
If the SBA never validly guaranteed the loan, then every representation treating it as guaranteed is false. That is a classic FCA fact pattern.
Why This Matters
The FCA does not require a formal demand for payment, an actual SBA payout, or SBA being named in a civil enforcement action. It requires knowing use of false records material to a federal obligation.
Eastern Bank used the existence of a supposed federal guarantee to justify enforcement, pressure settlement, resist defenses, escalate costs, and pursue liens against a homestead. That reliance itself is material under the FCA.
Latent leverage anchored in financial-regulatory reality, not theory.
All four cases remain live. Opposing parties have failed to lawfully plead.
Rule 55(a) defaults are live or imminent across all dockets.
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