Our adversarial system “rel[ies] on the parties to frame the issues for decision.” United States uv. Sineneng-Smith, 590 U.S. 371, 375 (2020) (quotation marks omitted). Courts “do not, or should not, sally forth each day looking for wrongs to right.” Jd. at 376 (quotation marks omitted).

Here, the district court found a genuine dispute of material fact about whether Petitioner was actively resisting arrest when he was tased, precluding a erant of qualified immunity to Respondents. Re- spondents argued on appeal that the district court had erred because non-video evidence (namely, the of- ficers’ affidavits and police reports) conclusively demonstrated that Petitioner was actively resisting arrest. The Court of Appeals lacked jurisdiction over this argument under Johnson v. Jones, 515 U.S. 304, 318 (1995). The Court of Appeals nonetheless re- versed the district court on other grounds, relying on its independent review of the record.

The question presented 1s:

Whether the Court of Appeals violated the party- presentation principle by reversing the district court on grounds never raised, and in fact affirmatively disavowed, by Respondents?

Petitioners are foreign liquidators seeking to recover assets for innocent investors in foreign-based funds who lost billions of dollars in the infamous Ponzi scheme orchestrated by Bernard L. Madoff. In related proceedings, the domestic SIPC trustee has recovered substantial sums for the benefit of U.S.-based victims of Madoffs fraud. But when petitioners invoked Chapter 15 of the Bankruptcy Code to seek assistance in asserting foreign-law claims for the benefit of foreign victims, the Second Circuit held that the Code extinguished those claims—even though the whole point of Chapter 15 is to facilitate international comity and recovery efforts by foreign liquidators. That decision turns Chapter 15 on its head and flouts bedrock principles of U.S. law. Notwithstanding the strong presumption against extraterritorial application of U.S. law, the Second Circuit atextually extended a “safe harbor” shielding domestic securities transactions from certain domestic-law claims to create a novel, U.S.-law defense to foreign-law claims targeting foreign conduct. Making matters worse, the court broke with every other court to address the issue in holding that the safe harbor’s restriction on the Code’s “avoidance powers’ directly bars common-law claims that exist irrespective of any bankruptcy. The upshot is that the promise of Chapter 15 is rendered ulusory and foreign victims of Madoff’s fraud are left holding the bag, while U.S. victims get meaningful relief.

The question presented 1s:

Whether the Bankruptcy Code’s safe harbor for securities settlement payments, 11 U.S.C. §546(e),

This petition presents the same question pending before this Court in Kingdom of Spain v. Blasket Renewable Investments, LLC, et al. (No. 24-1130) on the proper interpretation and application of the arbitration exception of the Foreign Sovereign Immunities Act (FSIA), which provides that a foreign state shall not be immune 1n an action to confirm an award rendered pursuant to “an agreement made by the foreign state with or for the benefit of a private party to submit to arbitration all or any differences *

• • between the parties.” 28 U.S.C. 1605(a)(6); Appendix (Pet. App.) 85a. This petition, however, presents the question from a_ different but complementary angle. While Blasket involves the foreign state’s legal authority to offer (consent) to arbitrate with investors from certain Contracting Parties under a multilateral investment treaty, this petition involves the legal authority of domestic investors to accept an offer to arbitrate under a bilateral investment treaty that by its terms extends only to foreign investors. Although Russia’s petition is independently certworthy, this Court would benefit from granting both petitions and hearing the cases together. That way it can conduct a 360-degree review of the relevant issues and fully resolve the existing circuit split on the question presented, which 1s:

Whether Section 1605(a)(6) requires a court to determine, as a threshold jurisdictional matter, that the foreign state offered (consented) to arbitrate “with or for the benefit of a private party” such that an arbitration agreement exists between those parties.

1. Whether a Constitutional challenge to the imposition of a new sentence on revocation constitutes, an “improperly raised collateral attack” on the underlying conviction and sentence?

2. Whether the district court relied on impermissible factors in revoking Mr. Simpson’s Supervised Release term, sentencing him, and imposing a new term of supervised release.

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