1. Does the doctrine of res judicata bar a Title VII retaliation claim based on post-employment conduct when the prior lawsuit addressed only pre-termination conduct, particularly when the subsequent claims were not ripe during the prior litigation?

2. Isa plaintiff required to amend an initial KLEOC charge to include distinct acts of post-employment retaliation, or may they file a separate EEOC charge without violating Title VII’s administrative exhaustion requirements?

3. Does the 300-day limitations period for filing an EEOC charge for a retaliatory lawsuit commence with a threat of litigation or with the actual filing of the lawsuit?

The trial judge entered an Order (App. 10a—21a) that deprived each of the three child Petitioners of their right to associate with their fit and loving father, Petitioner Sherman, and deprived him of his right to care for the children.

The Supreme Court of Virginia entered an Order (App. la—5a) that found, enter alia, the trial court Order (App. 10a—21a) did not violate procedural due process by taking evidence from one parent and not the other before issuing a child custody order from the bench.

Do the Fifth and Fourteenth Amendments require pre-deprivation due process before a court enters a child custody order that infringes fundamental liberty interests of both a fit parent and a minor child and severs the relationship between the child and fit parent?

At the time of the Founding, the common law prohibited the execution of “idiots.” Ford v. Wainwright, 477 U.S. 399, 417 (1986). In Ford, this Court made clear that “the Eighth Amendment’s ban on cruel and unusual punishment embraces, ata minimum, those modes or acts of punishment that had been considered cruel and unusual at the time that the Bill of Rights was adopted.” Ford, 477 U.S. at 405. Relying on these fundamental principles, Mr. Black in the lower courts sought the opportunity to demonstrate that the Eighth Amendment prohibits his execution. The Tennessee Supreme Court “declined” to recognize this common-law prohibition on his execution or permit Mr. Black to prove that he qualifies for such protection. It held that competency to be executed proceedings are limited to “Ford-based claims of incompetency grounded in insanity|,]” thus eliminating consideration of any common law claim other than one based upon significant mental illness. Black v. State, No. M2000-00641-SC-DPE-CD, 2025 Tenn. LEXIS 279, at *24 (Tenn. July 8, 2025). Given this, the question presented 1s:

Whether a state may refuse to provide a process by which a state inmate

may prove that he is not competent to be executed because he meets the

common law standard for the protection of “idiots”?