1. Whether a federal district court errs in eranting summary judgment based upon the improper application of McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), which runs contrary to the pronouncements in McDonnell- Douglas itself, Title VII, Reeves v. Sanderson Plumbing Products, Inc., 530 U.S. 1838 (2000), and further runs afoul of the Seventh Amendment right to a jury trial with the misapplication of Federal Rule of Civil Procedure 56.

2. Whether a federal district court may ignore state law to enforce a purported contractual six-month limitations period, despite a three- year statute of limitations for state discrimination claims, where there are genuine factual disputes as to whether the plaintiff knowingly agreed to such a waiver and which is contrary to state law, as in the recent Michigan Supreme Court precedent in McMillon v. City of Kalamazoo, 983 N.W.2d 79 (Mich. 2028).

A criminal defendant’s “right to counsel” under the sixth Amendment “is the right to the effective assistance of counsel.” Strickland v. Washington, 466 U.S. 668, 686 (1984) (citation omitted). This Court has recognized that an _ attorneys deficient investigation may prejudice a criminal defendant even though the attorney later asserts that an adequate investigation would not have “altered their chosen strategy.” Wiggins v. Smith, 539 U.S. 510, 536 (20038). In the decision below, the Seventh Circuit assumed that trial counsel for Petitioner William T. Hudson, III, performed deficiently by failing to investigate and present the testimony of Hudson’s sister, Dana—who “was arguably ‘the only [] witness|] that [clould have corroborated [Hudson’s] theory of defense.” App. 27a (alterations in original). The Seventh Circuit nevertheless held that Hudson was not prejudiced because trial counsel “did not believe that Dana’s testimony was necessary.” App. 9a-10a.

The Question Presented 1s:

Whether a court evaluating an_ ineffective assistance of counsel claim may rely on the testimony of counsel who has failed to conduct an adequate investigation in determining whether there was prejudice stemming from that deficiency.

1. Whether a state court may constitutionally refuse to act on a properly filed Petition for

Declaratory Judgment regarding private trusts and fiduciary control without violating the

Due Process Clause of the Fourteenth Amendment. 2. Whether prolonged judicial silence constitutes a constructive denial of access to remedy,

violating the First, Fifth, and Fourteenth Amendments and Missouri Constitution Article |,

Sections 10 and 14. 3. Whether refusal to recognize valid trust instruments and fiduciary designations

constitutes an unconstitutional impairment of contracts under Article |, Section 10 of the

U.S. Constitution. : 4. Whether a state court’s inaction in a matter involving federal constitutional rights,

property rights, and Indigenous claims amounts to a functional bill of attainder in

violation of Article |, Section 9 of the U.S. Constitution. 5. Whether Missouri’s judiciary, by wholly refusing to address a pro se indigent petitioner’s

filings and hardship claims, has surrendered state sovereignty in this matter and

triggered federal supervisory jurisdiction under Article Ill, Section 2 of the U.S.

Constitution. 6. Whether an emergency situation such as this permits the Court to expedite process and

procedure in order to prevent ongoing harm.

1

(1) | Whether the California courts’ and Ninth Circuit’s rejection of an Ex Post Facto Clause claim—where a more punitive law was applied at sentencing, eliminating a prior statutory eligibility for probation—violates clearly established U.S. Supreme Court precedent.

(2) | Whether procedural default based on California’s contemporaneous objection rule applies to federal ex post facto claims, particularly where trial counsel’s failure to object constituted ineffective assistance of counsel, forfeiting any opportunity to request probation on three lewd act convictions.

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