“[Wlhen it comes to the Fourth Amendment, the home is first among equals.” Florida v. Jardines, 569 U.S. 1, 6 (2013). As this Court has repeatedly stressed, “the sanctity of a person’s living space” is entitled to “special protection.” Lange v. California, 594 U.S. 295, 303 (2021). Given that “centuries-old principle,” the right “to retreat into [one’s] own home and there be free from unreasonable government intrusion” lies at the “very core” of the Fourth Amendment. Id.

Here, at 3 a.m. and without a warrant, law-en- forcement officers brought a trained drug-detection canine to sniff the front door of Eric Tyrell Johnson’s apartment home in the locked hallway of a multi-unit building. They sought to gather information about the interior of Mr. Johnson’s home. The dog alerted to the presence of illegal substances inside—information of- ficers could not have otherwise gathered without physically entering the home. In the Second and Sev- enth Circuits and in Illinois and Texas, the officers’ conduct would have been a Fourth Amendment search requiring a warrant or an exception to the warrant re- quirement. But the Fourth Circuit below joined the Eighth Circuit and the high courts of Maryland, Min- nesota, and North Dakota in holding that using a drug-detection canine at the door of an apartment home is not a Fourth Amendment search. In so doing, the court rejected Justice Kagan’s concurrence in Jardines, 569 U.S. at 12-16, and deepened the split.

The question presented is whether police conduct a Fourth Amendment search when they use a drug- detection canine to sniff the door of an apartment home in a multi-unit building to determine whether there 1s contraband inside.

Does the Due Process Clause of the Fourteenth Amendment to the United States Constitution allow a state to exercise specific personal jurisdiction over a non-resident retail seller of legal, non-defective, easily- transportable products based on the seller’s foreseeability that some such products may, through the agency of third parties over whom the seller has no control, be transported into the forum state without any direction from the seller?

For years, Petitioner Youth 71Five Ministries received grant funds from Oregon’s Youth Com- munity Investment Grants program. One year, 71F ive even had a top-rated application. But that all changed when Respondents added a new eligibility rule that prohibits grantees from “discriminating” in employment based on religion. That rule stripped 71F ive of already-awarded grants and disqualified it from further grants because the Christian ministry requires all employees to sign a statement of faith.

A Ninth Circuit motions panel granted 71Five an injunction pending appeal. But the merits panel disagreed and affirmed the district court’s denial of an injunction as to grant-funded initiatives and dismissal of 71Five’s damages claim, finding the new erant rule neutral and generally applicable. The merits panel further held that the religious-autonomy doctrine can only be asserted as an affirmative defense to a lawsuit, not to stop unconstitutional government action when it occurs. That ruling presents two questions for the Court’s review:

1. Whether a religious organization can raise the First Amendment right to religious autonomy as an affirmative claim challenging legislative or executive action under 42 U.S.C. 1983, like other constitutional right, or whether the doctrine may only be asserted as an affirmative defense after a suit has been filed, as the Ninth Circuit held here.

2. Whether a state violates the First Amendment by conditioning access to a public grant program ona religious organization waiving its right to employ coreligionists, including for ministerial positions.

1. Whether a court conducts an adequate inquiry into juror racial bias where it dis- counts evidence of racial bias as “off-hand” remarks, relies upon the prevalence of racial bias in American history, and weighs evidence of racial bias against evidence of defendant’s guilt?

2. Whether the Illinois court properly found that evidence of extraneous influence on juror deliberations was disproved beyond a reasonable doubt?

This Court’s decision in Miranda v. Arizona, prescribed that “A suspect must be warned prior to any questioning . . . that if he cannot afford an attorney one will be appointed for him prior to any questioning if he so desires.” 384 U.S. 436, 479 (1966) (emphasis added). The question presented asks:

Whether law enforcement’s advisement to a defendant that entirely

omits the “if he so desires” language regarding the right to appointed

counsel satisfies law enforcement obligation to communicate the

Miranda warning before interrogating an individual in its custody?

1

1. Whether 18 U.S.C. § 922(g)(1) violates the Second Amendment when applied to an individual based on his past conviction for a non-violent offense.

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

1

Accordingly, the Petitioner respectfully prays that he be allowed to dispense with the affidavit requirement, pursuant to Rule 39(1) of this Honorable Court.

Respectfully Submitted, in San Juan, Puerto Rico, this 29th day of December 2025. José R. Olmo Rodriguez CA1-79544 261 Ave. Domenech, SJ PR 00918 787.447.9914/jrolmol@gmail.com

2

QUESTION PRESENTED Roberto Lopez-Ortiz is serving life in prison for an offense that no longer exists. He fully preserved his challenge to second-degree felony-murder at trial and, while his direct appeal was pending, the state supreme court abolished that offense for the same reasons that he asserted. Consistent with due process, must this substantive change to the offense apply to him on direct review?