The Petitioner, Timothy Carver (“Mr. Carver’) was indicted on charges of Production of Child Pornography, Distribution of Child Pornography, and Possession of Child Pornography. The charges were due, in part, to Mr. Carver’s sexual contact with his minor grandson. Dr. Katie Osborn Spirko, a forensic and clinical neuropsychologist, testified that at the time of the offenses, Mr. Carver was suffering from a behavioral variant of frontotemporal dementia, a debilitating, progressive neurodegenerative disease that caused a severe mental defect in Mr. Carver which rendered him completely incapable of understanding what he was doing or that 1t was wrong.

The United States elected not to have Mr. Carver independently evaluated or offer any expert testimony as to Mr. Carver’s mental condition, instead focusing on the outrageous nature of Mr. Carver’s conduct, which was not 1n dispute. Despite the extensive expert testimony presented by the defense, the jury rejected Mr. Carver’s insanity defense, and he was _ sub- sequently sentenced to 460 months of incarceration.

The Questions Presented Are:

1. Whether the appellate court erred in affirming the district court’s rejection of Mr. Carver’s insanity defense, where expert medical testimony established that Mr. Carver suffered from a progressive, degenera- tive brain disease which rendered him incapable of understanding the wrongfulness of his actions at the time of the offense, as required by 18 U.S.C. § 17?

2. Whether due process permits a jury to reject an affirmative insanity defense supported by clear and convincing medical evidence, when the government

This case concerns the constitutionality of geofence warrants. For cell phone users to use certain services, their cell phones must continuously transmit their exact locations to their service providers. A geofence warrant allows law enforcement to obtain, from the service provider, the identities of users who were in the vicinity of a particular location at a particular time.

In this case, law enforcement obtained, and served on Google, a geofence warrant seeking anonymized location data for every device within 150 meters of the location of a bank robbery within one hour of the robbery. After Google returned an initial list, law enforcement sought— without seeking an additional warrant—information about the movements of certain devices for a longer, two-hour period, and Google complied with that request as well. Then—again without seeking an additional warrant—law enforcement requested de-anonymized subscriber information for three devices. One of those devices belonged to petitioner Okello Chatrie. Based on the evidence derived from the geofence warrant, petitioner was convicted of armed robbery.

The questions presented are:

1. Whether the execution of the geofence warrant

violated the Fourth Amendment.

2. Whether the exclusionary rule should apply to

the evidence derived from the geofence warrant.

Petitioners Breanna Renteria and Laura Smith joined a ministry with fellow Christian believers to share healthcare costs. Petitioners’ religious beliefs compelled them not only to share these costs, but to abstain from health insurance that requires insureds to subsidize religiously objectionable treatments. The Affordable Care Act (“ACA”) expressly recognizes such ministries, defining them as health care sharing ministries (“HCSMs’). By participating in their ACA- allowed HCSM, Petitioners are not only exempt from the ACA’s individual mandate to obtain minimum essential coverage, they also enjoy statutory protections for their religious exercise. This protection was suddenly threatened, however, when the New Mexico Office of the Superintendent of Insurance ordered Petitioners’ ministry to either cease in-state operations or comply with the New Mexico Insurance Code—an act that would effectively kill the HCSM. Petitioners sought a preliminary injunction, which the district court denied. On review, the Tenth Circuit, over the dissent of Judge Carson, imposed heightened requirements on Petitioners to prove the law was not neutral or generally applicable under Employment Division v. Smith, 494 U.S. 872 (1990), and determined that New Mexico’s decision to block ACA-exempt organizations from operating in in its borders was not preempted by federal law. Ultimately, it found Petitioners unlikely to succeed on the merits of their claims.

The questions presented are:

1. Under Smith, whether state laws must always be deemed “neutral” unless plaintiffs prove officials acted against them with subjective religious animus and discriminatory motive.

1. This Court has repeatedly held that the government may not confer a benefit conditioned on the waiver of a constitutional right. A blood draw isa highly intrusive invasion of bodily integrity for which a warrant is generally required. Under Georgia’s implied consent statute, a driver arrested for driving under the influence who refuses to consent to a blood draw has his driver’s license suspended for at least a year and the refusal may be used as evidence of guilt at a criminal trial. Does the Georgia statute violate the unconstitutional conditions doctrine?

2. Consent is one of the exceptions to the Fourth Amendment’s warrant requirement. This Court has repeatedly held that, to be valid, consent must be siven voluntarily and not as a result of duress or coercion. Under the Georgia implied consent statute, a driver who refuses to consent to a blood draw faces an automatic suspension of his driver’s license of at least one year and having his refusal admitted as evidence of guilt at a criminal trial. Are these substantial adverse consequences of refusal to consent impermissibly coercive so as to render consent involuntary?

During a press conference convened by the New York Attorney General to announce the filing of a civil lawsuit against Red Rose Rescue, a pro-life organization, and several of its members, the Attorney General declared that the organization was a “terrorist group” and that those associated with the organization were “terrorists.” There were no allegations of terrorism in the civil lawsuit, and neither Red Rose Rescue nor anyone associated with the organization has ever been charged with the crime of terrorism nor any other violent felony. The Attorney General’s appellation was designed to malign Red Rose Rescue and its associates in the eyes of the public and to reduce the effectiveness of their First Amendment activities.

1. Do Petitioners, who are members of Red Rose Rescue, have standing to advance their constitutional challenge to the actions of the Attorney General when they have alleged a chilling effect on their First Amendment rights and reputational harm?

2. Are the Attorney General’s “terrorist” and “terrorist group” designations opinion protected by the First Amendment and thus immune from New York’s defamation law?

that finally determine substantive rights including conversion, striking, and public disclosure orders.

3. Whether the First and Fourteenth Amendments and art. I, § 23 protect privacy in cause-of-death information and beneficiary identity in : probate records and prohibit State retaliation against a crime victim in | custody proceedings for reporting her rape as well as State retaliation against the Petitioner for exposing the those retaliations. |

4. Whether Fla. Stat. § 732.802 disqualifies the decedent’s rapist and ex- fiancé from inheriting from Dana G. Butler’s estate and whether custody and benefit orders can be reviewed if Petitioner is barred from speaking on Butler’s behalf, leaving her and her children without constitutional protections.

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Petitioner was charged in a four-count indictment with various offenses related to child pornography. He exercised his Sixth Amendment right to trial. Prior to trial, the Government failed to disclose information regarding a second expert witness in a timely fashion. Rather than exclude that witness’ testimony and allow Petitioner to proceed to a trial he was ready for, the district court continued proceedings. At trial, with the Government’s case strengthened by its late disclosed evidence, Petitioner was acquitted on two counts and convicted on two others, including possession of child pornography on a particular date when the evidence showed no active files on Petitioner’s computer that he could access.

This Petition presents two issues:

I. Whether a district court abuses its discretion by continuing a case following the Government’s late disclosure of an expert witness whose testimony substantially strengthened its case, rather than granting Petitioner’s motion to exclude that witness’ testimony and proceed to trial as scheduled.

II. Whether a person knowingly possesses child pornography, in violation of 18 U.S.C. § 2252A, on the date charged in the indictment based on images on his computer that were not accessible to the average computer user.

_l-

a. When the undisputed factual record demonstrates the denial of the constitutional right to testify at a capital trial, but the State courts find to the contrary, do the federal courts err in affording deference to the State courts?

b. Where there is disagreement among lower courts on the type of error that occurs when the right to testify is denied, as well as on the appropriate way to ensure the vindication of the right, should this Court grant certiorari to establish a uniform understanding and protection of the right?

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a. Is a capital defendant’s waiver of mitigation adequately knowing, intelligent, and voluntary when the waiver is predicated on a fundamental misunderstanding of proceedings and the utter dissolution of the attorney-client relationship?