1. Did the District Court unreasonably deny Plaintiffs arguments that newly discovered evidence should require a) reversal of prior dismissal; and b) allow for discovery on the newly discovered evidence?

2. Did the District Court err by refusing to a) address the recusal/disqualification motion by labeling it “moot”; and b) should Judge Edmonds recuse/ disqualify herself from this matter?

1.In Estelle v. Gamble, 429 U.S. 97 (1976), this Court held that the government has an obligation to provide care for the serious medical needs of incarcer- ated people. The question presented is whether jail mental health providers’ obligations under Estelle are limited to “protection from violence and suicide.”

2.In Bell v. Wolfish, 441 U.S. 520 (1979), this Court held that jails may not subject pretrial detainees to conditions that amount to punishment. Absent an in- tent to punish, this determination will turn on “whether an alternative purpose to which [the re- striction] may rationally be connected is assignable for it, and whether it appears excessive in relation to” that purpose. The question presented is whether re- strictlons ostensibly imposed for suicide prevention nonetheless comprise unlawful punishment when they are excessive in both nature and duration rela- tive to that purpose, and also deprive an inmate of the “minimal civilized measure of life’s necessities.”

3.In NRA of America v. Vullo, 602 U.S. 175 (2024), this Court reiterated that in reviewing a 12(b)(6) mo- tion to dismiss, courts must draw reasonable infer- ences 1n the plaintiffs favor and consider the allega- tions as a whole. The question presented is whether a court may categorically disregard any inference as to an actor’s state of mind as “speculative,” 1rrespec- tive of the plaintiffs allegations.

in D.C. Supervised by attorney admitted in D.C. BROCK MASON

QUINN EMANUEL URQUHART

& SULLIVAN, LLP 2755 E. Cottonwood Pkwy Salt Lake City, UT 84121 (801) 515-7324 March 18, 2026 Counsel for Petitioner