This Court has numerous precedents establ- ishing binding national jurisdiction relating to matters of federal law and the Constitution. In Accardi v. Shaughnessy, this Court’s ruling requires administrative agencies to follow their own binding rules and procedures. This doctrine is not vahd, if the violation failed to cause prejudicial or due- process harm to the affected person. Additionally, in Marbury v. Madison, this Court’s ruling established Judicial Review. Which determined, courts are required to interpret and expound on the law. The above precedents of this Court, were set in place to protect societies fundamental constitutional rights.

The questions presented are:

1. Did the court exceed their authority by affirming the concerning practice of agencies and courts acting outside their own statutory laws, when determining the fate of families and in direct conflict with this Court’s precedent the Accardi doctrine?

2. Did the state courts conflict with this Court’s precedent when violating Marbury v Madison by failing to interpret and expound on the law?

oH Did the courts fail to apply Strict Scrutiny and the Matthews Standard to substantiate the determinations alleged by the state; when they moved to remove the child on an unsubstantiated finding of imminent harm, in an unusual situation violating the family’s fundamental due process rights?

4. Did the Superior Court err when it failed to address the Plain Error caused by the prejudicial erroneous misclassification of the mother and father’s expert witnesses, which fundamentally harmed their case, affecting the outcome?

1. Whether private plaintiffs may maintain a suit in equity for declaratory and injunctive relief against state actors to prevent the continued enforcement of a state law preempted by Section 208 of the Voting Rights Act, 52 U.S.C. § 10508.

2. Whether Section 208 of the Voting Rights Act, 52 U.S.C. § 10508, is enforceable by private plaintiffs.

1. Whether a court of appeals may, by clerk correspondence rather than judicial order, refuse to : accept for filing or to docket a timely petition for panel rehearing—contrary to FRAP 25(a)(4) and 40(d)(1)—thereby departing from the accepted and usual course of judicial proceedings under Supreme Court Rule 10(a). |

2. Whether, by foreclosing filing and leaving , no judicial rehearing order, a court of appeals may defeat the operation of Supreme Court Rule 13.3

and thereby preclude review absent this Court’s : supervisory intervention. i |

In 2010, Congress amended the False Claims Act’s public-disclosure provision to expand—rather than limit—the class of whistleblowers who may proceed when elements of a fraud have entered the public do- main. By redefining “original source” to include those “who [have] knowledge that is independent of and ma- terially adds to the publicly disclosed allegations or transactions,” 31 U.S.C. § 3730(e)(4)(B), Congress en- sured that meritorious actions would not be foreclosed merely because prior disclosures permitted an infer- ence of fraud. Preserving actions based on independ- ent, non-public information that materially enhances the government’s understanding of a fraud ensures that the False Claims Act continues to serve its fun- damental purpose—protecting the public fisc by un- covering and deterring fraud against the United States.

The question presented 1s:

Whether the requirement in 81 U.S.C. § 87380 (e)(4)(B) that a relator have “knowledge that is inde- pendent of and materially adds to the publicly dis- closed allegations or transactions” requires a distinct inquiry into whether the relator’s non-public infor- mation meaningfully contributes to the government’s understanding or ability to act on the publicly dis- closed information, as applied by a majority of cir- cults, or whether overlap with public disclosures bars the action, as applied by other circuits?

1. Whether a legal argument concerning the standard of review may be deemed waived, notwithstanding that other courts of appeals— including the Sixth and Seventh Circuits—have held that the standard of review is not waivable.

2. Whether a court, 1n reviewing an administrative order, may substitute its own determination in place of an agency’s missing determination on a dispositive issue, notwithstanding that 5 U.S.C. § 706 limits the court’s role to review.

3. Whether 17 C.F.R. § 240.21F-13 may be interpreted to permit the SEC to withhold portions of the administrative record from judicial review.

4. Whether a pattern of disregard for a petitioner’s legal and factual arguments may deprive the petitioner of a meaningful hearing and violate due process.

2. Whether the District Court’s prohibition against presenting a defense of |

mistake of age violated the Defendant’s Sixth Amendment Right to , present a defense? LIST OF PARTIES TO THE PROCEEDINGS |

Petitioner, the Defendant/Appellee below, is Pierre Burns. : Respondent is the United States of America. 2 LIST OF PROCEEDINGS -

1. Sixth Circuit Court of Appeals, Case No. 24-5558, United States of America v. ! : Pierre Burns, 2025 WL 2954569 (6th Cir. Oct. 20, 2026). | |

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2. United States District Court for the Middle District of Tennessee, Case No. _ 3:22-CR-00069, United States of America v. Pierre Burns, final judgment a entered June 7, 2024. :

3. United States District Court for the Middle District of Tennessee, Case No. : 3:22-CR-00069, United States of America v. Pierre Burns (M.D. Tenn. oe December 21, 2023) (Motion in Limine Hearing on Government’s Motion to , Exclude Defendant’s Knowledge of The Minor Victims’ Ages and the Minor i Victims’ Consent); Order entered January 8, 2024. _

1. Given the absence of probable cause to arrest here, and/or the right to seize, and/or the right to shackle here (and detain and the like, as was done here) and given the fact of a lack of probable cause: can it be said, as it was (with impunity) that: the basis for the seizures, the arrest, the confinement, the illegal search, and to detain arguably was not violated here, indeed with impunity.

2. Whether given the extreme vacillation, by the Government, on the existence of probable cause to Arrest and to Seize here, coupled with the indisputable failure to Mirandize issues, and given these findings (that probable cause to arrest and/or seize were said not to exist here) and given our contention, the State also failed to show its presence in any of the respects it was required to prove its existence, the fact of their non-presence must be validated.

3. Given, Miranda v. Arizona, 384 US 436 (1966), was, in our judgement, ignored, with impunity, it follows here any assumption that could be done with impunity (as it was here) — as it was by these Courts, violated Due Process.

4. Whether, given the arrest, the seizures and the detentions (shown to have occurred here) were indeed condemnable as we say: one thing is clear. It is beyond dispute that various rights related to Boyer-Letlow’s (our Petitioner) were egregiously violated. And, given that reality 1s, and was so, it inexorably follows; none of these convictions can survive meaningful scrutiny. For sure then, and so postured, this case should be reviewed. Indeed, it is beyond dispute that these men were clearly stopped, seized and arrested, indeed by Federal Agents who were clearly acting on their own authority. And, with that being so,

1. Whether the District Court erred in dismissing Petitioner’s habeas petition on Younger abstention grounds without addressing the threshold question of whether California Penal Code Section 1485.5 creates a collateral estoppel effect that binds the State to factual concessions made in prior state habeas proceedings—an issue of first impression that no court has ever decided.

2. Whether the Ninth Circuit erred in denying a Certificate of Appealability when the District Court’s failure to address the novel Section 1485.5 question, combined with Petitioner’s substantial Double Jeopardy claim based on binding prosecutorial concessions of fabricated evidence and insufficient evidence, establishes that reasonable jurists would debate both the procedural! ruling and the underlying constitutional claim

: under Slack v. McDaniel, 529 U.S. 473 (2000).

3. Whether the Double Jeopardy Clause of the Fifth Amendment bars retrial when the prosecution’s binding Nonopposition under California Penal Code Section 1485.5—if accorded collateral estoppel effect—establishes that (a) the trial judge and prosecutors conspired to rig the trial through ex parte communications, fabricated evidence, and , altered transcripts and; and (b) the evidence was insufficient to sustain the conviction without the fabricated evidence, thereby triggering protection under Burks v. United States, 437 U.S. 1 (1978), and Oregon v. Kennedy, 456 U.S. 667 (1982).

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The landmark case of Morrissey v. Brewer, 408 U.S. 471 (1972), established due process safeguards for conditional lib- erty revocation hearings. It outlawed the prior practice by which a parole officer could secure revocation through an ex parte submission and held that revocation proceedings must be decided by a neutral and detached arbiter based on evi- dence presented at a hearing. Morrissey and its progeny are embodied in Federal Rule of Criminal Procedure 32.1 and 18 U.S.C. § 8583.

In its opinion below, the First Circuit recognized that the district court had learned new facts ex parte from a fact-wit- ness: Petitioner’s supervising probation officer. The district court then consulted ex parte with that probation officer, the government’s primary fact witness, in assessing both revo- cation and the appropriate punishment.

The question presented 1s:

Does a district court violate the Fifth Amendment’s neutral-and-detached-arbiter requirement, as recognized in Morrissey, when it engages 1n ex parte communications with a fact-witness probation officer to consider factual allegations and determine the punishment for revocation?

1

QUESTIONS PRESENTED | QUESTION 1: WHETHER, IN THE UNIFORM CODE OF MILITARY JUSTICE, THE CLAIMS OF JUDICIAL BIAS AND IMPROPER REFERRAL OF CHARGES ARE JURISDICTIONAL IN NATURE. QUESTION 2: WHETHER THE UNITED STATES COURT OF APPEALS FOR THE TENTH CIRCUIT’S USE OF THE FACTORS ENUMERATED IN DODSON V. ZELEZ, 917 F.2D 1250 (10TH CIR. 1990), KNOWN COEQUALLY AS THE “DODSON FACTORS”, CREATES AN UNCONSTITUTIONAL BAR TO HABES REVIEW FOR MILITARY COURT MARTIAL PETITIONERS IN VIOLATION OF THE SUSPENSIONS CLAUSE OF THE US. CONSTITUTION, ARTICLE 1 § 9 CL. 2. |

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| Questions Presented |

I. Can U.S.S.G. §1B1.13(b)(6) be held to be an “excess of author- ity” by the Commission when Congress has reviewed and rati- fied that guideline pursuant to 28 U.S.C. $994?

Il. Does the 8th Circuit’s practice of denying pro se inmates

the opportunity to brief their appeals violate the Due Pro- cess Clause of the 5th Amendment and the Federal Rules of | Procedure?

III. Does a summary denial bereft of reason satisfy the require- ment of “Rita v. United States,” 551 US 338 (2007) that the record reflects the Court considered the parties’ arguments? |

, F |