In 1907 Florida instituted its closed-primary system now embodied in Fla. Stat. § 101.021. This was five years after the White Primary was fully established in Florida. Charles D. Farris, The Re-Enfranchisement of Negroes in Florida, 19 THE JOURNAL OF NEGRO HISTORY 2 62-63 (1954). The birth of the Florida closed- primary system was also eighteen years before this Court applied the protections of the First Amendment to the states in Gitlow v. New York, 268 U.S. 652 (1925)

The Questions Presented are:

1. Does the Petitioner have standing to sue the Florida Secretary of State in his official capacity as chief election officer of the state for any violation of Petitioner’s rights under the First Amendment and Equal Protection Clause to vote in primary elections to determine candidates for political offices in general elections?

2. Does the Florida closed-primary system violate Petitioner’s rights under the First Amendment and Equal Protection Clause to political free speech and association?

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Does a person who engages in otherwise lawful, consensual sex with a 16 or 17-year-old dating partner commit “sex-traffickinge’ if the person’ gives unconditional gifts to the date?

May a person be convicted under 18 U.S.C. § 1591(a), for the sex trafficking of a minor without knowledge that a minor would be caused to engage in a commercial sex act?

As discussed in a nearly-identical, unopposed petition (24-1192), the extent to which federal courts can exert power over third-party claims and claimants 1s a question of national significance that has arisen with increasing frequency in a variety of contexts.

This Court has itself curtailed multiple courts’ attempts to exercise authority over objecting parties or non-parties the last two terms. Trump v. CASA, Inc., 145 S.Ct. 2540 (2025) (courts can award complete equitable relief only to parties); Texas v. New Mexico, 602 U.S. 948 (2024) (settling parties cannot dispose of non-settling objectior’s claims); Harrington v. Purdue Pharma L.P., 603 U.S. 204 (2024) (bankruptcy code does not’ permit nonconsensual release of third-party claims).

Five circuits have also issued conflicting decisions on courts’ equitable authority over third- party claims, but in the equitable receivership arena—when courts appoint receivers in SEC enforcement actions to manage distressed debtors’ assets, then oversee their division among creditors. The Fifth, Tenth, Eleventh, and now the Ninth Circuit permit federal receivership courts to approve a receivers settlement with a non-receivership entity that enjoins third-party claims against that entity without the claimants’ consent. But the Sixth Circuit forbids the nonconsensual release of claims that belong to a third party in the name of equity. The question thus presented, and ripe for review, 1s:

Whether a federal court overseeing an equity receivership has equitable authority to dispose of claims that belong to a third-party against non- receivership entities without the claimants’ consent.

A panel of the United States Court of Appeals for the Ninth Circuit unanimously held that the RICO limitations period began to run when Petitioner first discovered that his father, aunt, and uncle, had conspired to strip real assets from his grandmother’s trust shortly before her death. The conspiracy was unsuccessful at the time and no actual injury occurred until the following year. The Panel paid lip-service to this Court’s decision in Rotella v. Wood, 528 U.S. 549, 555 (2000) that only the discovery of injury starts the RICO clock. It ignored Petitioner’s prompt inquiry when he first learned of the conspiracy, and his retention of counsel, imputing knowledge of the later injury to him notwithstanding his inquiry. The timeliness and reasonableness of his inquiry were not addressed by the District Court or the Panel. It then found that his allegations of fraudulent concealment were insufficient, and that post-mortem looting of the personal assets of the trust did not give rise to “new and independent” claims entitled to separate accrual of the limitations period, even though neither issue had been addressed below.

The questions presented are:

1. Does the inquiry notice doctrine allow a court to start the RICO limitations period before discovery of any actual injury?

2. Did Singleton v. Wulff, 428 U.S. 106, 120 (1976) require the Panel to remand the case to the District Court to consider the issues it had not previously addressed?

1. Whether the government’s prosecution of petitioner under 18 U.S.C. § 922(g)(1) based on his prior convictions violates the Second Amendment.

2. Whether application of 18 U.S.C. § 922(g)(1) to petitioner violated the Commerce Clause where the only proof of a nexus between his firearm possession and interstate commerce consisted of the fact that the firearm had crossed a state line at some point before coming into petitioner’s possession.

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