Clean Air Act §307(b)(1)’s typical claims-process rule requires petitioning for review within 60 days of final action of the Administrator. Since 1990, unique among such forms of review, administrative petitions to reconsider do not stay an action’s finality. In 2022, EPA staff erred factually and legally by denying an informal Administrative Procedure Act (“APA”) adju- dication to enter a new program with annual distribu- tions, which petitioner immediately met with staff to correct, following up by administratively petitioning to correct within the 60-day window. When EPA is- sued the next year’s distribution without deciding the administrative petition, he sued for constructive de- nial, which the D.C. Circuit found jurisdictionally barred by the 60-day window and §304(a)(2), another 1990 Clean Air Act provision, which expanded district court jurisdiction for failure to take nondiscretionary action. The present petition for review challenged not only the 2022 staff action but also EPA’s 2024 denial of two of four then-pending administrative petitions.

In both petitions for review, the Court of Appeals eranted EPA’s motions to dismiss without the admin- istrative record, over petitioners’ objection. A record would have shown that subordinate staff without the Admiunistrator’s delegated authority took the 2022 ac- tion and that nothing hinged on the partial 2024 de- nial in isolation (i.e., EPA could grant the two pending petitions before the next annual distribution).

The questions presented for summary decision are:

1. Whether this Court’s supervening decision on nonjurisdictional 60-day windows bars res judicata?

2. Whether review of action unlawfully withheld remains under §307(b)(1) or moved to §304(a)(2)?

Under Florida v. J.L. 529 U.S. 266 (2000), 911 callers must provide a modicum of factual details describing criminal conduct for Police to effect a lawful Terry v. Ohio, 392 U.S. 1 (1968) “detention.”

In 42 U.S.C. 1983 litigation, Discovery responses, Discovery answers, formal policies, and documents can concede issues of fact, law, and elements of claims. Most relevant; they are party statements and not hearsay. (1) Whether a 911 call which did not describe criminal conduct, did not describe the actor, nor provide any address can give rise to a legal Terry uv. Ohio, 392 U.S. 1 (1968) “detention” and justify subsequent Police conduct? (2) Whether a party’s repeated assertions that a city’s formal policies and training directed their conduct serve as Monell admissions of liability in the presence of Fourth Amendment violations?

The Third Circuit held that the Commonwealth of Pennsylvania is vicariously liable for violations of Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act committed by third-party contractors providing medical services to inmates in state prisons. That holding deepened an acknowledged circuit split, and is inconsistent with this Court’s prec- edents. But no party raised the issue of derivative lia- bility at any point during this litigation. Instead, one week before argument, the Third Circuit sua sponte identified that unraised issue and inserted it into the case by requiring the parties to address it. That egre- 210uUs violation of the party presentation principle war- rants summary reversal under United States v. Sineneng-Smith, 590 U.S. 371 (2020), and Clark uv. Sweeney, 607 U.S. 7 (2025) (per curiam).

The questions presented are:

1. Did the Court of Appeals violate the party presen- tation principle by sua sponte inserting the derivative lability issue into the case?

2. Are public entities and recipients of federal fund- ing vicariously liable for Title II and Section 504 viola- tions committed by third-party contractors?

1

The Federal Arbitration Act (FAA) reflects “a liberal federal policy favoring arbitration agreements.” CompuCredit Corp. v. Greenwood, 565 U.S. 95, 98 (2012) (quoting Moses H. Cone Mem Hosp. v. Mercury Constr. Corp., 460 U.S. 1, 24 (1983)). Courts must “examine with care the complaints seeking to invoke their jurisdiction in order to separate arbitrable from nonarbitrable claims.” KPMG LLP v. Cocchi, 565 U.S. 18, 19 (2011). “[I]f a dispute presents multiple claims, some arbitrable and some not, the former must be sent to arbitration even if this will lead to piecemeal litigation.” Id.

The Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA) permits plaintiffs to void an arbitration agreement “with respect to a case which is filed under Federal, Tribal, or State law and relates to [a] sexual assault dispute or [a] sexual harassment dispute.” 9 U.S.C. § 402(a).

The questions presented are:

Should claims within the scope of an arbitration agreement that are unrelated to sexual assault or sexual harassment continue to be arbitrated under the FAA? Put differently, can the EFAA (a limited exception to the FAA) apply to non-sexual assault and harassment claims?

If the EFAA can apply to claims that are not related to sexual assault and harassment claims, is it proper for a plaintiff to amend a complaint solely to evade arbitration by invoking the EFAA?

, In Smith v Bennett, 365 US 708 (1961), this Court determined that equal force of review apply to state post-conviction, so does Michigan state courts’ summarily denial of constitutional errors without a merit determinations amount to a review under the due process and equal protection clauses?

i.

1. Whether U.S.C.A. Const. Amend. 14 requires state prosecutors to disclose material exculpatory evidence to criminal defendants before the entry of a guilty plea, particularly when a defendant has filed a motion for discovery and Brady material before entry of the guilty plea?

2. Whether a Brady claim following a guilty plea is legally cognizable where the suppressed evidence was the cause without which the defendant would not have entered the guilty plea?

3. Whether the Due Process Clause requires disclosure of material exculpatory evidence to a defendant before entry of a guilty plea a question the Supreme Court left open in Ruiz but on which federal circuits have reached divergent outcomes, and which a Louisiana decision applied in a way that forecloses aclaim basedona pre-plea discovery violation.

2

lf the District Court (Judge Wicks) uses an email with incorrect data to build his criteria and dismiss the case, should a revision of the facts be allowed? This is of significant importance nationwide because it is a Federal violation to disregard medical accommodations Question 2:

Plaintiff’s director and manager participated in a sinister setup in which they used pretext to convince and deceive their HR department and later, the various Courts. There is evidence in the case documents that Judge Wicks observed how Russo spoke with their HR department

, about not allowing Plaintiff to participate in various meetings (Final Written Warning) where Plaintiff was getting framed. Judge Wicks said in his report (doc 157) that in this case, we cannot take action because Director Russo is involved.

Question 3:

One of the arguments Judge Azrack used to deny Plaintiff’s case said: “The submitted Doctor’s note reflects a lack of diligence by Plaintiff given that it predates Plaintiffs extension request by twelve days.”. Plaintiff did not mean harm. His only objective was to show good cause and that his symptoms were and are persistent every day, multiple times a day, with unexpected increases in frequency and potency. This included before, during, and after Plaintiff’s deadline. To clarify, Plaintiff got the doctor’s confirmation of the date when they adviced him to get medical help.

Can this reason for denying the case be reviewed? Question 4:

There are other statements on the closing arguments of Judge Wicks and Judge Azrack that Plaintiff would like to show they were pretextual. Is it acceptable if Plaintiff files a Motion and describes the various issues there? |

9 the Assistant United States At++o (veda boot ch; being able ta stillebtai, (a2 0 irearmMms with another claim even thou h she . knew tha+ the Kine and ATE already disposed

sthis Firearms or sale on aAUction earlier in the year, SO the Filth Circe i$ Court protected the Assistant United States Attorney by automatically dismissin chi’s appeal his firearms go tha they wouldn + lave +e address er (ies,

Should the Fifth Circuit Court be. allowed to automatically dismiss Op reals solely to cover UP the. government’s (vest | 3 ‘ The district Court overlooked the FRI’s Jou 2, 2024-, P, operty Claim Directive then wrong ily considered anold case trom

Ut

1. Whether Federal Rule of Civil Procedure 6(b)(1)(B) — which requires a motion and a showing of “excusable neglect” to consider a filing after a deadline — may be bypassed without motion or findings, thereby nullifying its mandatory gatekeeping function.

2. Whether a federal appellate court may allow Rule 12 dispositive motions to proceed despite being untimely under Rule 12(a), without requiring defendants to move under Rule 6(b) or show cause, effectively making the deadlines discretionary.

3. Whether permitting such silent deadline forgiveness introduces non-uniformity across federal courts, undermining the purpose of the Federal Rules of Civil Procedure and | inviting widespread procedural abuse.

4. Whether a decision like this, published and indexed on govinfo.gov and PACER, has nationwide persuasive authority and institutional impact, regardless of its “unpublished” designation, warranting this Court’s intervention.

\

Title 42 U.S.C. §1983 provides broad redress to compensate for violations of individuals’ constitutional rights. This Court, in Monell v. Dept of Soc. Servs. of N.Y., 486 U.S. 658 (1978), indicated that Section 1983 suits against municipalities are actionable only against unconstitutional polices or customs. It has never extended that holding to private corporations that contract with state or municipal entities to provide governmental services. The question presented is: Whether private prison medical providers are shielded from respondeat superior suits under Section 1983.

1

NYSRPA v. Bruen, 597 U.S. 1 (2022), represented a sea change in Second Amendment jurisprudence, instructing courts to uphold only those firearms regulations that are “consistent with this Nation’s historical tradition of firearm regulation.” Looming large post-Bruen was its application to 18 U.S.C. § 922(g¢)(1), the federal statute that prohibits anyone previously convicted of “a crime punishable by imprisonment for a term exceeding one year” from possessing a firearm. That statute divests millions of Americans from exercising their Second Amendment rights for life, and prosecutions under § 922(¢g)(1) account for over 10% of federal criminal cases. In other words, § 922(g)(1) 1s arguably the most important single firearm regulation in American law. And, yet, this Court has not heard a single § 922(g)(1) case post-Bruen.

Without guidance, courts have struggled to apply Bruen to this hugely impactful statute, leading to intractable conflict and highly divergent outcomes. Thus, it is now impossible for millions of Americans to predict whether they are permitted to exercise a core constitutional right or whether they will be imprisoned for doing so.

To that end, the question presented 1s:

Whether 18 U.S.C. § 922(¢)(1) violates the Second Amendment either facially or as applied to individuals with convictions for non-violent offenses.