1. WHETHER THE A STATE MAY PROHIBIT A CRIMINAL DEFENDANT FROM COMPELLING THE PRODUCTION OF LAW ENFORCEMENT VIDEOS TO THE DEFENDANT’S TRIAL WHERE THE STATE HAS ESTABLSIHED AN ANCILLARY PROCEEDING FOR OBTAINING COPIES OF THE VIDEOS?

2. WHETHER THE NORTH CAROLINA SUPREME COURTS’S DECISION THAT THE “EXCLUSIVE MECHANISM” FOR OBTAINING LAW ENFORCEMENT VIDEOS THROUGH AN ANCILLARY PROCEDURE DIVESTS A TRIAL COURT OF AUTHORITY TO ORDER THE PRODUCTION OF THOSE VIDEOS PURSUANT TO PENNSYLVANIA V. RITCHIE?

In Societe Internationale Pour Participations Industrielles et Commerciales, S.A. v. Rogers, 357 U.S. 197, 207 (1958), the Court held that a federal court’s authority to dismiss a case for discovery noncompliance arises from Rule 37, not from Rule 41(b) or any free-floating “inherent power.” In Chambers v. NASCO, Inc., 501 U.S. 32, 46 (1991), in a 5-4 decision, the Court pushed back and “discern[ed] no basis for holding that the sanctioning scheme of the statute and the rules displaces the inherent power to impose sanctions for the bad-faith conduct.”

The questions presented are:

1. Whether an imposition of sanctions against a party and not its attorney under a court’s inherent authority can be upheld by the mere talismanic recitation of the phrase “bad faith” when courts are in conflict about whether an inherent-authority sanction requires bad faith and when the appeals court does not rely on the district court’s key finding on bad faith.

2. Whether an imposition of sanctions under a court’s inherent authority can be affirmed based on conduct that was not sanctionable under Federal Rule of Civil Procedure 37.

Minnesota enacted a law prohibiting employers from requiring employees to attend meetings in which the employer discusses its views on political or religious matters — otherwise known as “captive- audience” meetings — and requiring them to post a notice written by the State notifying employees of this law. The law clearly violates this Court’s precedent declaring that employers have a First Amendment right to communicate their views to employees. Petitioners brought suit in federal court against Respondents who maintain enforcement authority over the law. Reversing the district court, the Eighth Circuit ordered dismissal of Petitioners’ suit, thereby conflicting with this Court’s holding in Whole Woman’s Health v. Jackson, 595 U.S. 30 (2021), and in further conflict with the Fifth, Sixth, Ninth, Tenth and Eleventh Circuits.

The question presented is whether state officials may disclaim enforcement authority over a law to avoid federal court review of the law’s constitutionality where the statute places clear enforcement authority over, or an obligation to enforce, the law with those state officials.

Petitioner Michael Newberry was a teenager when he was convicted of capital murder on the theory that he and his co-defendant, Lilton Deon Moore, mur- dered the victim in the course of committing a rob- bery. Nearly thirty years into Mr. Newberry’s life sen- tence, the State of Texas—for the first ttme—produced the testimony Moore gave to the grand jury that the state habeas court determined “removes the aggravat- ing element of robbery.” The court found that the trial prosecutor knowingly withheld Moore’s testimony and police statement, and that the evidence was favorable and material. Joining in Petitioner’s request for relief, the State admitted that its conduct violated Brady uv. Maryland, 373 U.S. 83 (1963), and deprived Mr. New- berry of a fair trial.

Despite the agreement of the Petitioner, the pros- ecution, and the habeas court, the Texas Court of Criminal Appeals (TCCA) denied relief, with one judge dissenting. The TCCA’s unsigned order contains no reasoning, fails to acknowledge the State’s confes- sion of error, and does not even cite the relevant legal standards. The questions presented are:

1. Where the Petitioner, the State, and the habeas court all agree that a con- viction 1s unconstitutional and must be reversed, does it violate due process for a state superior court to summarily deny relief without explanation?

2. Did the prosecution violate Brady v. Maryland, 373 U.S. 83 (1968), by sup- pressing evidence contradicting its proof

J. Whether federal courts violate due process and equal protection by denying in forma pauperis status based on gross income that includes mandatory payments under jurisdictionally void orders, when the IFP denial forecloses the § 1983 action seeking to challenge state actors’ unauthorized exercise of power and prevents access to | discovery documenting the jurisdictional violations.

II. Whether M.L.B. v. S.L.J.‘s prohibition on wealth barriers to fundamental rights adjudication extends to § 1983 claims challenging state actors’ deprivation of parental rights through jurisdictionally void orders issued without subject-matter jurisdiction and without constitutionally mandated procedural safeguards.

III. Whether state actors violate § 1983 when they exercise authority over an interstate child removal after an appellate court orders a mandatory jurisdictional hearing that never occurs, issue orders without subject-matter jurisdiction, and deprive a parent of fundamental liberty interests without due process, creating a federal question that is not barred by Rooker-Feldman or the domestic-relations exception. |

i

del, Deniel by Vistrict Cort of Plafte COUT, Ne, App eer iW State Conf, enw, awe | Supreme of cout of Webresk Den s/

Laven cf he- CYS wet at nne- Lh; le (oowete ten, awd Whe Lane Cog F gnaw ted KAY,

Sudges fatlef | } | tha t L AWW disabit; ly of fs Al aU NAN —Vdge Cason mwed 4.9 S 7 prene / A f WV bye,

Yl thom dented. a by

id the hake Counsty States Attorney S olfice of Thwais 7 = Cr ae laaeate taank ag Violate Taceb A-Aubiais Exh AMewdmenk cightt oF Corfentiation at Civd afdor af Protection MAUR ON Mardy OU 20t4 cask 2oleoP 22(LI

C Hecke ly Ata irsd eat mens Aide aukcame Or +AU ON

Cage +e Zo} croeeoZeIS Peoole v. Muar . (ath 23 ACC al cit wast coulk LC wat Coudy ait Lonukkecjond Tllwors Geces — bake (ouviy *

1. In dismissing Petitioner’s U.S.C. § 2254 Application, and , denying a certificate of appealability, has the district court and the Fifth Circuit Court of Appeals violated the Supreme Court’s precedents long standing?

2. As pointed out in the bestselling book, “The Scales of + Injustice: The Raymond Lumsden Story,” and throughout =the pleadings in the Texas and United States Court’s, did the

Petitioner’s trial attorney with permeated failures and incompetence, fundamentally flaw the defense in violation of Petitioner’s constitutional right to a fair trial and to have effective assistance of counsel? oo oe , 3. Was Petitioner entitled to a certificate of appealability , (COA) under Supreme Court precedents Martinez; Trevino; and Slack ?

4. Should Petitioner have been appointed counsel to assist him in his § 2254 proceedings after having made several requests — due to the significance and complicated matters raised?

1. To determine a controlled substance offense under USSG § 4B1.2(b) using the categorical approach, do courts compare the elements of the prior conviction to substances that were controlled on the date of the prior conviction, or to the substances controlled on the date of federal sentencing?

2. Does the undefined term “controlled substance” in USSG § 4B1.2(b) take its ordinary meaning, or the statutory definition in the Controlled Substances Act, 21 U.S.C. § 802(6)?

3. Does the undefined term “distribution” in USSG § 4B1.2(b) take its ordinary meaning, or the statutory definition in the Controlled Substances Act, 21 U.S.C. §§ 802(8), 802(11)?

1

Whether Petitioner was derived of his right, under the Sixth and Fourteenth Amendments, to a trial by a 12-person jury when the defendant is charged with a serious felony?

There are two other petitions raising the same question presented. See Parada v. United States, No. 25-166; Minor v. Florida, No. 24-7489. This case should at least be held pending resolution of those petitions.

il

In Batson v. Kentucky, 476 U.S. 79 (1986), this Court held that racially motivated peremptory challenges by the government violate the equal protection rights of a defendant and undermine public confidence in the judicial system. As such, whenever a defendant prevails on a Batson claim, the court must impose a remedy—lest it preside over a trial tainted by racial discrimination.

In the decision below, the Second Circuit acknowledged this well-settled principle. Yet when asked to apply it to a situation in which defense counsel made two successful Batson claims but allowed them to go unremedied, it took the unprecedented position that such a failure was excusable because it may have been part of some undisclosed defense strategy. In its view, requiring that attorneys demand a remedy after prevailing on their Batson claims would “trap” them between “competing obligations—Batson on the one hand, the client’s best interests on the other.” Defense counsel must be able to strategically forego a Batson remedy, excuse the government’s racial discrimination, and have their clients appear before juries empaneled in violation of the Equal Protection Clause so as to avoid this “tension,” says the Second Circuit.

The question presented is as follows:

Whether an attorney has necessarily provided ineffective assistance of counsel when, after making successful Batson claims, he fails to insist on a remedy and allows his client to be tried by a jury selected by racially discriminatory means?

1. Whether a defendant previously convicted of a felony offense violates 18 U.S.C. §§ 922(¢)(1) & 924(a)(2) when, at the time that he possesses a firearm, he honestly but mistakenly be- heves that his civil rights (including his right to possess a fire- arm) have been restored.

2. Whether petitioner’s guilty plea was not knowing, intelligent, and voluntary because he erroneously was led to believe that he was guilty of violating 18 U.S.C. §§ 922(¢)(1) & 924(a)(2), de- spite the fact (as the district court found) that, when petitioner possessed the firearm, he honestly but mistakenly believed that his civil rights had been restored.

3. Whether the Ninth Circuit erroneously presumed that, before petitioner pleaded guilty, his defense counsel had properly explained the mens rea element of the charge under 18 U.S.C. §§ 922(¢)(1) & 924(a)(2), when the record clearly rebuts that presumption.

4. Whether, as several other circuits have held, an appellate walver provision in a plea agreement does not apply to a defendant’s substantial claim on appeal that he is actually innocent of the offense to which he pleaded guilty; or, instead, as the Ninth Circuit held in petitioner’s case, such an appellate waiver applies to a substantial claim of actual innocence.

in

1. Whether a magistrate’s issuance of a dispositive custody and support order—adopted the

same day by an administrative judge without a hearing—violates the Due Process Clause of

the Fourteenth Amendment and Ohio Civ.R. 53(D). 2. Whether a court’s failure to serve summons, hold a hearing, or permit objections prior to

entering binding custody and child-support orders violates procedural due process.

3. Whether suspension of a parent’s driver’s license for child support based on an order

issued without notice, evidence, or a hearing violates the Fourteenth Amendment under Bell

v. Burson and Mathews v. Eldridge.

4, Whether a judge’s refusal to rule on timely motions for recusal and disqualification | violates a party’s right to an impartial tribunal under the Due Process Clause.

5. Whether the Supreme Court of Ohio’s summary dismissal of a mandamus petition

alleging structural constitutional defects provides adequate review consistent with 28 U.S.C.

§ 1257(a). :

, did the Minth Circuit Court of Appeals current adjudication, coupled with the | . Nistrict Court’s decision denying petitioner’s claim heyond addressing the merits, adversely infringe upon petitioner’s genuine right to liherty, inclusive to a further deprivation of petitioner’s equal orotection ant “ne process rights guaranteed hy the 5th and 14th amendments to the nites States Constitution?