This Petition asks the Court to consider the following questions:

1. Have various State and Federal Courts, when asked to apply The General Aviation Revitalization Act of 1994,’ inconsistently legislated from the bench by denying litigants a right to ajury trial once an initial determination has been made that an issue of fact has been created by the replacement of parts with new?

2. Have various State Federal Courts, when asked to apply The General Aviation Revitalization Act of 1994, inconsistently denied litigants a right to jury trial once there has been an issue of fact created by evidence that information required by the FAA for certification or continuing airworthiness of an aircraft has been knowingly withheld by a manufacturer?

3. Is there a split amongst the Federal Circuit Courts of Appeals and State Appellate Courts in the application of the Rolling Provision and Knowing Misrepresentation Provision of the General Aviation Revitalization Act of 1994 such that some deny a litigant the right to a jury trial once an issue of fact is raised by evidence thus denying these litigants procedural and substantive due process?

4. Is there a denial of procedural and substantive Due Process when a Court in interpreting the application of the General Aviation Revitalization Act of 1994 decides

5. The General Aviation Revitalization Act, Pub. L. No. 103- 298, 108 Stat. 155, 49 U.S.C. § 40101, note.

The federal bank robbery statute, 18 U.S.C. § 2113(a), imposes criminal liability on “[w]hoever, by force and violence, or by intimidation, takes, or at- tempts to take, … or obtains or attempts to obtain by extortion any property or money … [from] any bank.” The so-called “elements clause” of 18 U.S.C. § 924(c) provides for enhanced sentencing penalties where a defendant uses or carries a firearm in relation to a “crime of violence,” which is defined in relevant part as a felony that “has as an element the use, attempted use, or threatened use of physical force against the person or property of another.” 18 U.S.C. § 924(c)(3)(A).

It is undisputed that § 2113(a) bank robbery “by extortion” cannot satisfy § 924(c)’s elements clause on its own and accordingly is not a “crime of violence” under § 924(c)(8)(A). The questions presented here, which are also presented in Armstrong v. United States, No. 24-__ (petition filed July 1, 2025), are:

1. Is federal bank robbery in § 2113(a) indivisi- ble, such that no form of bank robbery qualifies as a “crime of violence” for purposes of § 924(c)?

2. If the statute is divisible, did the Eleventh Circuit err 1n holding that attempted federal bank rob- bery necessarily includes “the use, attempted use, or threatened use of physical force,” such that it qualifies as a “crime of violence” for purposes of § 924(c)?

The Small Business Administration’s Section 8(a) Business Development Program provides valuable benefits to small businesses owned by individuals deemed “socially disadvantaged.” Members of favored racial and ethnic groups are presumed to be disadvantaged, while other applicants must prove it. Small businesses in the program receive exclusive access to contracts with the federal government and other training and business development opportun- ities.

Marty Hierholzer, a service-disabled veteran, has twice been denied entry to the program after SBA concluded that evidence of his social disadvantage was insufficient. The Fourth Circuit held that he lacks standing to challenge the race-based rule that un- equally excuses some applicants from demonstrating their social disadvantage.

The question presented 1s:

Whether a small-business owner who was denied entry into SBA’s Section 8(a) Business Development Program for failing to prove “social disadvantage” has Article III standing to challenge a_ race-based presumption that excuses certain applicants from making that showing.

like circumstances, disclosure is forbidden.

The questions presented are:

1. Do multiple appellate decisions interpreting FERPA conflict with both Gonzaga and the congressional intent underlying FERPA?

2. Do appellate decisions like this one make state PRAs a substantial obstacle to achieving the congressional intent underlying FERPA?

3. Does it violate the Supremacy Clause of the UNITED STATES CONSTITUTION, ARTICLE VI, CLAUSE 2, to impose state fines, fees, and penalties on a school district for complying with federal law?

QUESTION PRESENTED FOR REVIEW

1. Did the U.S. Court of Appeals for the District of Columbia Circuit (“DC Circuit’’) err by affirming the order of the U.S. District Court for the District of Columbia (“District Court”) adopting Magistrate Judge Michael G. Harvey’s Report and Recommendation regarding

Defendants’ Motion for Attorney’s Fees and Costs?

The Wyoming Supreme Court has consistently decided an important federal question in a way that conflicts with the decision of other state courts of last resort and, more importantly, decisions of the Supreme Court of the United States. In Alleyne v. United States, 570 U.S. 99, 113 (2013), the Court appeared to put to rest any confusion as to what constitutes an element of a crime by explaining, if a fact is by law essential to the penalty, it is an element of the offense and that, “the core. crime and the fact[s] triggering the mandatory minimum sentence together constitute a new, aggravated crime, each element of which must be submitted to the jury.” [d. Despite the Courts holding, some States continue to reallocate the burden of proof with respect to its graded offenses—forcing defendants to disprove aggravating factual predicates to mitigate ones’ sentence. An affirmative defense with mitigating circumstances is an aspect that was left unaddressed in Alleyne. The affirmative defense — sentence mitigation issue in Patterson v. New York, 432 U.S. 197 (1977), was wrongly decided and deserves universal criticism because it continues to allow States to manipulate substantive elements of crimes. As Justice O’Connor wrote in her Apprendi v. New Jersey dissent, 530 U.S. at 544, it would require the Court to overrule, at a minimum, decisions like Patterson and Walton v. Arizona, 497 U.S. 639 (1990). Justice O’Connor’s intuition was spot-on— Walton and a host of others have since been overruled in the wake of Apprendi and its progeny.

The questions presented are: | 1. Whether this Court should resolve a controversial split, amongst State Courts of Last Resort, when State kidnapping statutes, having been influenced by federal law, unconstitutionally provides for an extended term of imprisonment by reallocating the burden of proof, requiring defendants to disprove aggravating predicates by a preponderance-of-the-evidence, while other States constitutionally mandate the State establish those same factual predicates beyond-a-reasonable- doubt.

2. Whether Wyoming Statute § 6-2-201 is unconstitutionally void for vagueness (due process) as written and applied, because the statutes inconsistent interpretations and contradictory applications violate the Sixth and Fourteenth , Amendments and are contrary to the holdings in Alleyne v. United States (20193); Apprendi v. New Jersey (2000); and Mullaney v. Wilbur (1975).

3. Whether this Court’s decision in Patterson v. New_York, 432 U.S. 197 (1977), should be clarified, limited or overruled.

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This petition presents two questions.

First, whether Almendarez-Torres vu. United States, 523 U.S. 224 (1998) should be overruled?

Second, whether this Court should grant certiorari, vacate the judgment be- low, and remand in light of Erlinger v. United States, 602 U.S. 821 (2024), if it does not elect a plenary grant of certiorari?

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When imposing maximum, consecutive sentences for two convictions for attempted interference with commerce by robbery (18 U.S.C. § 1951)—arising out of two discrete events taking place on two different nights—did the District Court abuse its discretion by implicitly premising its sentencing on an erroneous application of the Federal Sentencing Guidelines and a pretextual consideration of 18 U.S.C. § 8553 factors exclusively related to the operative facts underlying one conviction but not the other?

II.

When imposing maximum, consecutive sentences for two convictions for attempted interference with commerce by robbery (18 U.S.C. § 1951)—arising out of two discrete events taking place on two different nights—did the District Court violate Petitioner’s Fifth and Sixth Amendment rights by applying the murder cross reference USSG § 2A1.1 based on dismissed charges that previously arose out of the operation of law instead of relevant conduct of Mr. Williams underlying those dismissed charges?

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