Isabella County confiscated the Pung Estate’s private home for approximately $2,200 in taxes and fees (that were never actually owed). The lower courts used the artificially depressed auction sale price rather than the property’s fair market value as the starting point for its damages calculation. The Sixth Circuit and others have held that the “fair market value” taken is not what is owed to begin to fulfill the constitutional compensatory obligation imposed by the Fifth Amendment. That defies this Court’s precedents. And if it is not taken within the meaning of the Fifth Amendment, it 1s otherwise an excessive fine under the Eighth Amendment by imposing a punishment by pilfering far more than ever needed to satisfy a small debt.

The questions presented are:

1. Whether taking and selling a home to satisfy a debt to the government, and keeping the surplus value as a windfall, violates the Takings Clause of the Fifth Amendment when _ the compensation is based on the artificially depressed auction sale price rather than the property’s fair market value?

2. Whether the forfeiture of real property worth far more than needed to satisfy a tax debt but sold for fraction of its real value constitutes an excessive fine under the Eighth Amendment, particularly when the debt was never actually owed?

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This case presents a classic vehicle for this Court to clarify that a judicial decision which changes legal precedent cannot be applied retroactively to divest a private party of vested rights. A judicial decision that changes legal precedent should only be applied retroactively where private rights have not vested.

This critical question cannot be presented more clearly than in this case. Here the Court can compare side-by-side two cases involving the same facts, same law, same injunction, same judicial panel, but different results solely because the Sixth Circuit Court of Appeals retroactively applied this Court’s recent decision in Lackey v. Stinnie,145 8. Ct. 659 (2025), and its new construction of 42 U.S.C. §1988, to deprive Petitioners of their vested rights.

The Questions Presented are as follows:

1. Whether retroactive application of Lackey uv. Stinnie, 1458. Ct. 659 (2025) and its new construction of 42 U.S.C. §1988, that results in the depravation of a vested, substantive, and unreviewable judgment to attorney’s fees violates the Due Process Clause of the Fourteenth Amendment.

2. Whether a judicial decision that changes legal precedent violates the Due Process Clause of the Fourteenth Amendment when it is_ applied retroactively to deprive a party of a vested right.

I. Whether accepting a defendant’s waiver of the right to a trial by jury and the jury’s full consideration of mitigating evidence 1n a death penalty case violates a defendant’s fundamental rights to a fair trial, individualized sentencing determination, and due process, as well as this Court’s requirement of voluntary, knowing, and intelligent waivers of constitutional rights, when the waivers are based on misinformation about an existing fact and that misinformation is not corrected before the waivers are accepted.

II. Whether, considering the operation and effect of Florida’s capital sentencing scheme, the Due Process Clause requires the factfinder to determine beyond a reasonable doubt that sufficient aggravating factors exist and that aggravating factors outweigh mitigating circumstances before the sentencer can choose to impose the death penalty, pursuant to Apprendi v. New Jersey, 530 U.S. 466, 476-85, 490, 494 n.19 (2000) and Ring v. Arizona, 536 U.S. 584, 603-05, 609 (2002).

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— 2. When the trial court is constituted by authority, and fails to address an asserted claim under associated authority, does this violates due process of the United States Constitutions 5” and 14 Amendments?

3. When the court exercise descretion to ignore lack of jurisdiction, is it a violation of the 1 5”, and 14° Amendment of the United States Constitution?
4. Did the 14” Amendment of the Constitution “equal protections of law” give cause _ under for the petitioner’s motion in this case, that provided challenge of state and federal jurisdiction to be proven? :
5. If the accusatory pleading is improper and it is raised in motion under supporting | authorities, does due process of the 5” and 14° Amendment of the United States Constitution requires proof of jurisdiction to appear on the record of the circuit, and | district court and all administrative proceedings? : | 6. If a judgment is void does the court act in a manner inconsistent with due process of the United States Constitutions 5” and 14” Amendments? |
6. When subject matter jurisdiction in a criminal case is invoked by the face of the accusatory pleading filed does a prosecution initiated from the face of an improper accusatory pleading violates due process of the United State Constitution’s 5” and 14” Amendments? ’
7. When a trial court.act beyond their authority and in contravention of it, in regards of a | lack of subject matter jurisdiction in the present case of the petitioner is it a violation of due process of the United States Constitution’s 5” and 14” Amendments?

1. Does State Judges have Jurisdiction over Veterans Benefits?

2. Does Absolute Immunity Apply when a judge has acted criminally under color of state law and without jurisdiction, as well as actions taken in an Administrative capacity to influence cases?

3. Does Title lV-D Falls Under Social Security Acts of 1975? |

4, Can Administrative Tribunal Judge have Immunity for their non judicial activities who knowingly violates a persons civil rights?

5. Do Administrative Tribunal Judge have to followed by Federal Laws, Supremacy Clause, Positive Law & Federal Preemption of State Jurisdiction?

6. We as citizen of the United States why do we have to abide by 7 Amendments and Constitutional Laws, when States Officials doesn’t follows by The Constitutional of Civil rights laws?

7. How can United States Court of Appeals for the 11” Circuit knows that the lower courts made errors in a lawsuit but wont advise the lower court in their erroneous?

8. Does the Higher Court knows what Veterans Judicial Review Act(VJRA) of 1988? |

9. If the Office of Child Support Enforcement (OCSE) have set the law stating that lower courts cannot garnished a Veterans Benefits, why are they not abiding by the Federal Laws?

1. Whether the Florida Supreme Court’s refusal to review Petitioner’s case permitted a violation of the Equal Protection Clause of the Fourteenth Amendment by allowing Florida’s lower courts to treat Petitioner differently from other similarly situated individuals in probate proceedings.

2. Whether the rulings of Florida’s lower and appellate courts, specifically the freezing of Petitioner’s accounts, the misapplication of controlling federal and probate law, and the imposition of severe financial burdens, violated Petitioner’s rights to procedural and substantive due process under the Fifth and Fourteenth Amendments.

3. Whether the Florida courts’ failure to address documented attorney misconduct, and the appellate court’s dismissal of Petitioner’s appeal solely due to counsel’s error, deprived Petitioner of her constitutional right to a fair hearing and meaningful access to justice.

4, Whether judicial misconduct and apparent bias by the lower courts resulted in arbitrary and capricious rulings that deprived Petitioner of fundamental rights under the Due Process and Equal Protection Clauses of the Fourteenth Amendment.

A geofence warrant, directed at a company such as Google, is a law enforcement tool used to obtain location history of user accounts via applications or programs active on someone’s cell phone or other device within a geographic area. Warrants of this nature are sweeping as they are limited only by geographic and temporal parameters. The Fifth Circuit has held that such warrants are categorically prohibited as they constitute general warrants in violation of the Fourth Amendment. United States v. Smith, 110 F.4th 817, 888 (5th Cir. 2024). But the Fourth Circuit, in United States v. Chatrie, 136 F.4th 100 (4th Cir. 2025) (rehearing en banc) (memo), and the Eleventh Circuit in this case, have rejected Fourth Amendment challenges, on varied and fractured grounds, to the use of geofence warrants. Is review warranted to resolve this discord among the circuits?

Il.

Does the record taken as a whole demonstrate improper collusion between federal and state law enforcement to make Davis’s arrest by state officers subject to the federal presentment requirements set forth in 18 U.S.C. § 8501(c) and Rule 5(a), Fed. R. Crim. P.?

III.

Whether Davis’s motion for judgment of acquittal should have been granted on the three carjacking counts for want of sufficient evidence that Davis had the intent to kill or seriously injury anyone?

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I. Whether the Fourth Circuit erred by dismissing Mr. Dickerson’s appeal, where the District Court improperly entered a $2,400,000.00 Order of Monetary Forfeiture based on insufficient evidence consisting of hearsay from felons and co-conspirators, speculation, guesswork, and “extrapolations” from so-called experts and Government witnesses?

ail

Petitioner received two sentences of death due to a bare majority jury recommendation of 7-5. On the third count, the jury recommended a life sentence without the possibility of parole. However, the trial judge decided to override the jurys vote and sentence Petitioner to death on the third count as well. Out of approximately 267 total death row inmates in Florida, Petitioner appears to be one of only 17 inmates whose death sentence results from a 7-5 bare majority jury vote, and/or a judicial override of a life sentence. The following question is presented:

Given that it 1s illegal to sentence an individual to death as the result of

a bare majority jury vote or judicial override of a life sentence anywhere

in this country, is 1t unconstitutional to execute Petitioner when his

death sentences stem from jury votes of 7-5 and 6-6?

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