The following excerpt is from U.S. ex rel. Sero v. Preiser, 506 F.2d 1115 (2nd Cir. 1975):
A number of other persuasive justifications enforce our conclusion that the class action device was appropriately used in this case. Because many of those serving reformatory sentences are likely to be illiterate or poorly educated, and since most would not have the benefit of counsel to prepare habeas corpus petitions, it is not improbable that more than a few would otherwise never receive the relief here sought on their behalf. See Developments in the Law-- Federal Habeas Corpus, 83 Harv.L.Rev. 1038, 1170-71 (1970); Adderly v. Wainwright, 58 F.R.D. 389, 405 (M.D.Fla.1972). Considerations of economy also argue persuasively for such a result. The considerable expenditure of judicial time and energy in hearing and deciding numerous individual petitions presenting the identical issue is thereby avoided, Williams v. Richardson, 481 F.2d 358, 631 (8th Cir. 1973), as is the expense which would be incurred in appointing counsel for each individual who proceeded on his own. 8
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