I have read that when the leaving group substituent is stuck in the equatorial position for some reason (like from a t-butyl group or a trans decalin), SN2 is either very slow or just doesn't happen at all because the rear attack is hindered by axial hydrogens/other substituents. I haven't been able to get a straight answer as to whether it can instead progress through SN1 at an acceptable rate, since the attached carbon will at least be secondary.
The only thing I can think of which would prevent this happening is the difficulty of forming a planar sp2 carbocation in a such a rigid system.
Any help is appreciated, thanks.