This case presents the same question that is

before the Court in Osabas-Rivera v. Bondi, No. 25-

(filed Mar. 4, 2026). For the reasons set forth in the petition in Osabas-Rivera, this Court should grant that petition and hold this case pending final resolu- tion of that case.

The question presented 1s:

Whether the application of 8 U.S.C. § 1158(a)(2)(D)’s “changed … or extraordinary circumstances” excep- tion to undisputed facts presents a “question|[]| of law” courts have jurisdiction to review under § 1252(a)(2)(D).

AND MARZIUANA CONSISTANT WITH THE FIFTH AND. FOURTEENTH | AMENDMENT ’S ?

2), WHETHER OR. NOT THE DEWTRICT COURT AND THE COURT bF APPEALS FOR. THE FOURTH CERCUZT ERRORED IN ConCLUDING THAT ADKZAS WAS PROPERLY SENTENCED BASED UPON THE EVIDENCE AND DENYING HIM VARIOUS SENZENCENE GUDDELINES REDUCTLOMS AND WHETHEM Of M07 HES SENTENCE. WAS SUBSTANTZUELY | REASONAPLE and LONGER. THAN NECESSARY 10 SATISFY 19 US C5383

3, WHETHER. OR. WOT THE CoURT OF APPEALS Fok. THE FOURTH | C2RCUT7T ERLORED IN I78 FEWDZNG SHAT SHE DESTRLICT COURT PRoPERLY CALUMATED ADLINS CRIMWVAL HISTORY, WHERE THE VA. CODE $46.2-357 L9o19) WAS REPEALED IN SULY AOR:

Title 18 U.S. Code § 922(g)(1) permanently disarms millions of Americans based solely on a prior felony conviction, without any individualized finding of present dangerousness. Under this Court’s decisions in New York State Rifle & Pistol Ass’n v. Bruen and United States v. Rahimi, modern firearm regulations must be consistent with the nation’s historical tradition of firearm regulation. The courts of appeals are deeply divided over whether § 922(g¢)(1)’s categorical lifetime prohibition satisfies that historical test. Therefore, the Question Presented 1s as follows:

Does the Second Amendment permit Congress to impose a permanent, categorical firearm prohibition based solely on a prior felony conviction?

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