--- title: "United States v. Holder" citation: "936 F.2d 1 (1st Cir. 1991)" authority_id: "AUTH-CA1-HOLDER-936-F2D-1" authority_type: "case" jurisdiction: "federal_first_circuit" precedential_status: "binding_in_ca1" url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA1-HOLDER-936-F2D-1/" legal_review: "2026-08-26" links_checked: "2026-10-15" links_available: 1 links_checked_count: 1 license: "CC BY 4.0" --- # United States v. Holder ## Holdings used - Assuming audita querela survives in federal criminal cases, it requires a legal objection arising after conviction that is not redressable through another postconviction remedy; purely equitable consequences are insufficient. ## Material limitation Binding only in the First Circuit and only for the bounded procedural postures in the linked claims. Published precedential full opinion reviewed from a public reporter reproduction after no stable historical official opinion file was located. Holder expressly left survival of the writ unresolved, rejected a pure-equity immigration-consequence theory, and identified no actual gap. A 2021 official First Circuit published opinion continued to cite Holder without adverse treatment. A comprehensive commercial citator was not run. ## Official source and pinpoints 936 F.2d 1 (1st Cir. 1991), 936 F.2d 2–5: ## Linked claims - `CLM-CIR1-006` ## Used in - [First Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/first-circuit.md)