1. Whether the National Labor Relations Act permits a finding that an employer has bargained in bad faith based solely on the substance of the company’s proposals on mandatory subjects of collective bargaining, without evidence of any bad-faith behavior away from the bargain- ing table.

2. Whether the Third Circuit’s “highly deferential” re- view of the National Labor Relations Board’s interpreta- tion of its statutory authority, which conflicts with the de- cisions of other courts of appeals, violates this Court’s holding in Loper Bright Enters. v. Raimondo, 603 U.S. 369, 412 (2024), that “[c]ourts must exercise their inde- pendent judgment in deciding whether an agency has acted within its statutory authority.”

3. Whether the National Labor Relations Board has the statutory or constitutional authority to order an em- ployer to pay consequential damages that employees incur as a result of an unfair labor practice.

I. Can a court of appeals disregard the government’s deliberate waiver of whether a jury trial right violation 1s harmless in the enhanced statutory penalty context and affirm over the government’s request that the defendant be resentenced without statutory enhancement?

Il. Should the Court overrule Neder v. United States, 527 U.S. 1 (1999), as inconsistent with Fifth and Sixth Amendment principles underlying this Court’s precedent in Apprendi v. New Jersey, 530 U.S. 466 (2000), and its progeny?

III. Does 18 U.S.C. § 922(¢g)(1) exceed Congress’s authority under the Commerce Clause, facially and as applied to Petitioner Samuel Storey’s intrastate possession?

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1. Whether U.S. Second Circuit Court of Appeals interfere with petitioner ability to file an appellate court brief as governed by the concept of proceeding in forma pauperis (IF P) under 28 U.S.C. 1915 and Federal Rule of Appellate Procedure (FRAP) 24 that allows IFP appellant parties to proceed with their appeal, file a brief, and use the original record and relevant lower court transcripts for the appealed issues raised by appellant in his brief that has been denied to be filed in violation of due process?

2. Whether the Fifth and Fourteenth Amendment of U.S. Constitution permits and allows a U.S. Citizen appellant party and/or IFP pro se party a right to file a appeals brief with and/or without a requested ordered transcript?

3. Whether U.S. Second Circuit Court of Appeals erred in its interpretation of IFP pro se appellant filed consolidated appeals of the reversible errors made by the late Honorable U.S. District Court Judge Jeffrey Meyer that was being addressed in appellant brief pending completed transcripts?

4. Whether U.S. Second Circuit Court of Appeals committed reversible error by dismissing petitioner appeal without allowing any appeals brief to be filed by appellant which is violation of petitioner right to due process?

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QUESTION PRESENTED Whether a capital postconviction defendant is entitled as a matter of due process and equal protection to records related to the state’s lethal injection protocols when any other member of the general public would be able to obtain the records under the rights provided by the state to open access of the government and public records?

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