A claim for First Amendment retaliatory arrest is typically not actionable unless the plaintiff proves the absence of probable cause. Nieves v. Bartlett, 587 U.S. 391, 403 (2019). Additionally, qualified immunity bars a retaliatory arrest claim unless the plaintiff demonstrates that the First Amendment right was so clearly established that any reasonable officer would know there was no probable cause to make an arrest. Reichle v. Howards, 566 U.S. 658, 664 (2012).

Here, the petitioner (a police officer) arrested the respondent (an individual filming the officer) for trespassing on private property. The respondent sued the petitioner for Fourth Amendment false arrest and First Amendment retaliatory arrest. The district court ruled that qualified immunity barred the false arrest claim because an objective police officer could have reasonably but mistakenly believed there was probable cause to arrest the respondent. Despite that finding, the court denied qualified immunity on the retaliatory arrest claim.

On appeal to the Ninth Circuit, a divided panel held that even if the petitioner acted reasonably but perhaps mistakenly in arresting the respondent—what many lower courts call arguable probable cause—the petitioner was not entitled to qualified immunity on the retaliatory arrest claim. This holding is contrary to decisions in the Fifth, Sixth, Seventh, Eighth, Tenth, and Eleventh Circuits.

The question presented is whether a police officer is entitled to qualified immunity from a retaliatory arrest claim when the officer could have reasonably but perhaps mistakenly believed there was probable cause for the arrest, and the Nreves exception does not apply.

This Court has long required that the exercise of personal jurisdiction over a defendant rest either on the defendant’s own suit-related contacts with the forum State (specific jurisdiction) or its own “continuous and systematic” affiliations that render it essentially at home there (general jurisdiction). The Court has never departed from that defendant-centric approach. And that approach forecloses the exercise of personal jurisdiction over Petitioner here. Indeed, it is undisputed that Petitioner itself has no forum contacts. Nevertheless, Respondents seek to assert personal jurisdiction by imputing an unaffiliated nonpartys contacts to Petitioner, based merely on Petitioner’s foreign acquisition of the nonparty’s assets and liabilities. The District Court heeded this Court’s unwavering focus on a defendant’s own forum contacts and rejected Respondents’ theory. But the Second Circuit reversed. In its view, if substantive “forum law” could hold a defendant “liable” for a nonparty’s actions, then the nonparty’s “related jurisdictional actions should also attach” to the defendant. That approach is inconsistent with this Court’s precedents and deepens an entrenched split among the lower courts.

The question presented is:

Whether the Due Process Clause allows courts to exercise personal jurisdiction by imputing an unaffiliated nonparty’s forum contacts to a defendant with no forum contacts of its own.

1. In determining whether the public has a right to access meetings of the Tennessee Judicial Advisory Commission, must a court apply the “experience and logic’ test prescribed by Rich- mond Newspapers Inc. v. Virginia, 448 U.S. 555 (1980), or is Houchins v. KQED, Inc., 488 U.S. 1, 15 (1978) still the governing rule?

In Johnson v. Jones, 515 U.S. 304 (1995), this Court held that, in interlocutory appeals from denials of qualified immunity, appellate courts lack jurisdiction to decide “whether or not the pretrial record sets forth a ‘genuine’ issue of fact for trial.” Id. at 320. The lower courts have divided over whether, and to what extent, there is an exception to that rule in cases involving video evidence.

The question presented is:

In an interlocutory qualified immunity appeal involving video evidence, under what circumstances, if any, may an appellate court review a district court’s determination that there is a genuine dispute of fact?

The common-law immovable-property rule pro- vides that sovereigns are not immune from suits relating to real property located in a_ foreign jurisdiction. In Upper Skagit Indian Tribe v. Lundgren, 584 U.S. 554 (2018), this Court left open the question of whether the immovable-property rule applies to an Indian tribe’s assertion of rights in non- trust, non-reservation real property. Id. at 559-61.

The question presented is:

Under the immovable-property rule, may a party sue an Indian tribe, without the latter’s consent, in a State court to quiet title to real property located in that State but which is not within the boundaries of the tribe’s reservation and is not held in trust by the United States?

This case presents a direct and acknowledged conflict over an important question of federal tax law. Under the Internal Revenue Code (Code), the Internal Revenue Service (IRS) typically has three years from the date a tax return 1s filed to assess tax. 26 U.S.C. § 6501(a). But Congress created an exception to that three-year deadline for “false or fraudulent return[s] with the intent to evade tax.” 26 U.S.C. § 6501(c)(1). If that exception applies, the IRS can seek unpaid tax at any time. In the decision below, the Third Circuit held that this exception applies broadly—and the sovernment faces no enforcement deadline at all—ifa third-party tax return preparer (unbeknownst to the taxpayer herself) intentionally prepared a “false or fraudulent return with intent to evade tax.” Under this rule, it makes no difference if a taxpayer is entirely innocent and has no knowledge about, let alone any participation in, any wrongdoing. In so holding, the Third Circuit created a direct split with the Federal Circuit, which held that § 6501(c)(1) applies only when the taxpayer herself acted with “intent to evade tax.” The decision below thus leaves the meaning of a central limitations period of the Code dependent on the forum in which a taxpayer litigates.

The question presented 1s:

Whether, under 26 U.S.C. § 6501(c)(1), the IRS may assess tax beyond the Code’s’ three-year limitations period based solely on the fraudulent intent of a third-party, even when the taxpayer herself neither intended to evade tax nor knew of any wrongdoing.

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1. Whether the Clean Water Act exempts from its National Pollutant Discharge Elimination System (“NPDES”) permitting program “discharges composed entirely of return flows from irrigated agriculture” as the statute expressly provides (83 U.S.C. § 1342(/)(1)), or instead exempts “irrigation return flows that do not contain additional point source discharges from activities unrelated to crop production,” as the Ninth Circuit interpreted the exemption to mean in this case? (App. 21-a.)

2. Whether the Clean Water Act’s exemption from its NPDES permitting program of “discharges composed entirely of return flows from irrigated agriculture” (33 U.S.C. § 1842(1))) exempts dispersed pollutants from non-farm sources that are collected and commingled with agricultural return flows before their discharge to waters of the United States?

3. Whether this Court’s ruling that under the NPDES permit program “a point source need not be the original source of the pollutant; it need only convey the pollutant to ‘navigable waters’” (South Florida Water Management Dist. v. Miccosukee Tribe of Indians, 541 U.S. 95, 105 (2004)) applies to the Clean Water Act’s exemption of “discharges composed entirely of return flows from irrigated agriculture’?

1. Whether a party seeking retrospective relief under Collins v. Yellen may prove causation through circumstantial evidence—or must produce direct evidence of presidential removal intent.

2. Whether the stigma-plus doctrine requires the same government actor to impose both stigma and deprivation—or permits claims when the elements are sufficiently connected.

I. To avoid dismissal of a § 1988 excessive-force suit, must a plaintiff plead, as an element of her claim, that the officer had a “superior alterna- tive” that would have avoided the harm?

II. To avoid dismissal under the “clearly estab- lished” prong of qualified immunity, must the plaintiff identify an identical fact pattern, as the Fifth Circuit continues to hold, or can prior prec- edent clearly establish a constitutional violation despite some factual variation?

(1)

| law as guaranteed by the Constitution under 42 USC §1983 by ‘engaging in inequitable and , racially discriminatory conduct, and subjecting plaintiff to discrimination and differential treatment in violation of the Equal Protection Clause such as being singled out and treated differently compared to all other persons within the city of Satsuma because of race, and color of skin. | Whether the lower court used an unfair application of the laws, and unconsciously integrated racial bias as compared to examining the elements of the claim to determine if the legal standards for this 42 USC §1983 claims were met? . Whether the lower court get it wrong in denying Plaintiff’s Motion for Equal Protection of the Law as it relates to the Civil Rights Claims Under 42 U.S.C. § 1983?

I. THE DISTRICT COURT COMMITTED PLAIN ERROR IN GIVING STANDARD

JURY INSTRUCTIONS THAT - WHEN READ IN CONJUNCTION WITH ONE

_ ANOTHER. PROVIDED INCORRECT OR CONFUSING STATEMENTS OF LAW. : . a .

_ II. THE DISTRICT COURT ERRED WHEN IT DENIED THE PETITIONER’S . . MOTION TO SUPPRESS EVIDENCE RELATED TO AN ILLEGAL SEARCH a : 4h ,

This Court has recognized that “no appeal waiver serves as an absolute bar to all appellate claims.” Garza v. Idaho, 586 U.S. 282, 238 (2019). But the Court has “ma[de] no statement … on what particular exceptions [to appeal waivers] may be required.” Id. at 238-39 & n.6.

In the absence of this Court’s guidance, the circuits have been intractably split over what exceptions to recognize for general appeal waivers. The Eleventh Circuit falls on the side with only narrow exceptions to appeal waivers and refuses to acknowledge an exception for miscarriages of justice.

The Question Presented is as follows: Is one of the permissible exceptions to a general appeal waiver a miscarriage-of-justice exception?!

1 This petition raises a similar question as Hunter v. United States, No. 24- 1063, which 1s scheduled to be orally argued on March 8, 2026.

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