: tutional rights in their appeal because of their counsel’s plain error in failing to address their rights in court. Their appeal drew strong attention to ineffective assistance of counsel.

3. Whether the 750 ILCS 60, the Illinois Domestic Violence Act as currently written, risks a fundamental deprivation of constitutional rights of freedom of | speech, freedom of religion, the right to keep and bear arms, the right to due process, and the right to equal ‘protection under the law, for respondents.

: 4. Whether the Illinois Appellate Court violated the petitioner’s rights by ignoring documented evidence of procedural irregularities and judicial mistakes pertaining to their case, and the Illinois Supreme Court in denying a review despite the provided evidence that supported their claims.

1. First Amendment exacting scrutiny requires a “substantial relation” between a campaign-finance disclosure regime and a_ sufficiently important governmental interest—namely, the informational interest in identifying those who support candidates for office. The question presented 1s whether New Mexico’s informational interest is sufficient under exacting scrutiny to justify applying its disclosure regime to issue advocacy organizations, like Petitioner, that engage 1n no express advocacy or its functional equivalent.

2. Under Buckley v. Valeo, campaign-finance disclosure requirements serve the government’s informational interest only when applied _ to organizations whose “major purpose’ is the election of candidates, or—for issue-advocacy organizations that lack that major purpose—when those organizations make expenditures that expressly advocate the election or defeat of a candidate. The question is whether applying New Mexico’s disclosure regime to an organization that does not meet Buckley’s “major purpose” test and does not engage in express advocacy, like Petitioner, constitutes narrow tailoring under exacting scrutiny absent donor earmarking.

3. This Court has long held that laws that burden political speech are subject to strict scrutiny, and, similarly, that content-based speech regulations are subject to strict scrutiny. The question is whether disclosure regimes applied to issue advocacy organizations, like Petitioner, that engage exclusively in political speech—without express advocacy or its functional equivalent—must satisfy strict scrutiny rather than exacting scrutiny.

Petitioner was charged in West Virginia with robbery committed by a particular means — by the threat of the use of force. At trial, the State proceeded on a different theory — that Petitioner had committed robbery by engaging in actual violence against the victim. Petitioner’s counsel did not object to this shift in the State’s theory and Petitioner was convicted and sentenced to more than a century in prison for that and related offenses. State and federal courts affirmed Petitioner’s conviction, concluding he had not received ineffective assistance of counsel.

This Petition presents the issue of whether a criminal defendant receives ineffective assistance of counsel when his counsel fails to object to the State’s shift in theory, from one method of committing an offense to another, where that shift deprives the defendant of the notice required by the Due Process Clause of the Fourteenth Amendment.

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THE PETITIONER, TIMOTHY WAYNE ROBINSON ARGUES ONLY ONE

ARGUMENT ABOUT EQUITABLE TOLLING AS TO WHY HE DESERVES EQUITABLE

TOLLING IN HIS CASE AT BAR.

PETITIONER TIMOTHY WAYNE ROBINSON HAS ONE MAIN QUESTION

FOR THIS UNITED STATES SUPREME COURT JUDGES AND THE QUESTION

IS THIS?

ARGUMENT | WHETHER THE PETITIONER QUALIFIES FOR EQUITABLE TOLLING FROM DECEMBER 2016, UNTIL MAY OF 2017, BECAUSE OF THE TIME FRAME THAT UNAVOIDABLY AROSE FROM CIRCUMSTANCES BEYOND THAT LITIGANT’S CONTROL? OTher Argu Len $&% ) oA f e

|

Did the First Circuit Err in Rejecting Petitioner’s Argument That the District Court Violated Due Process and the “Opportunity to Be Heard” Principle by Denying the Pro Se Prisoner’s Motion for Compassionate Release Immediately after a Government Opposition Was Filed, Effectively Preventing a Reply?

¢

Enacted in the Sentencing Reform Act of 1984, 18 U.S.C. § 3582(a) de- clares that “imprisonment is not an appropriate means of promoting correction and rehabilitation.” In Tapia v. United States, this Court held that “the Sen- tencing Reform Act precludes federal courts from imposing or lengthening a prison term in order to promote a criminal defendant’s rehabilitation.” 564 U.S. 319, 321 (2011).

The Courts of Appeals are split 5 to 7 over how to apply that rule. See United States v. Schonewolf, 905 F.3d 688, 691 (8d Cir. 2018) (cataloguing the split as of 2018). Today the Sixth, Ninth, Tenth, Eleventh, and D.C. Circuits understand Tapia and § 3582(a) to prohibit any reliance on rehabilitation when imposing a prison sentence. Meanwhile the First, Second, Third, Fourth, Fifth, Seventh, and Eighth Circuits take the “intermediate position,” Esteras v. United States, 606 U.S. 185, 190 n.1 (2025), that Tapia and § 3582(a) forbid only prison sentences based primarily on rehabilitation.

The question presented 1s whether any reliance on rehabilitation when imposing a prison term violates 18 U.S.C. § 3582(a).

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