In Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971), the Court recognized an implied cause of action under the Fourth Amendment against Federal Bureau of Nar- cotics agents who entered the plaintiff’s home without a warrant, conducted a search, and then arrested him—in front of his children— without probable cause. In this case, federal law enforcement officers entered Petitioner’s home without a warrant, searched the premises, and separated her from her children. While inside the house, one of the officers falsely claimed that Petitioner had just confessed to a crime and used that as a pretext for taking her into custody. As in Bivens itself, no probable cause existed for the arrest.

The questions presented are:

1. Whether Bivens provides a remedy when fed- eral officers enter a home without a warrant, fabricate evidence during the search, and use that evidence to arrest the resident without probable cause.

2. Whether the availability of an alternative rem- edy independently forecloses a Bivens claim that does not otherwise meaningfully differ from Bivens itself.

Whether a taking has occurred under the categor1-

cal rule announced by this Court in Lucas v. South

Carolina Coastal Council, 505 U.S. 1008 (1992), even

though the regulated property retains significant

market value for both its transferable development rights and recreational uses. (1)

This Court has repeatedly held that the Second Amendment protects a general right to bear arms in public for self-defense. New York State Rifle & Pistol Assn., Inc. v. Bruen, 597 U.S. 1, 33 (2022). Our Nation’s historical tradition of firearms regulation includes restrictions on possession in certain “sensitive places,” which have been identified as schools, courthouses, legislative assemblies, and polling locations. District of Columbia v. Heller, 554 U.S. 570, 626-27 (2008); Bruen, 597 U.S. at 30. This Court has cautioned however, that “expanding the category of ‘sensitive places’ simply to all places of public congregation that are not isolated from law enforcement defines the category of ‘sensitive places’ far too broadly.” Bruen at 31. But courts have done just that. Illinois’ First District Appellate Court has upheld a ban on firearms in public parks that imposes felony penalties for possession of any ready-to-use firearm, finding such a ban constitutional because public parks are a sensitive place. App.1. The First District adopted the Ninth Circuit’s reasoning in Wolford v. Lopez, 116 F.4th 959 (9th Cir. 2024), cert. granted in part, 146 S. Ct. 79, 222 L. Ed. 2d 1241 (2025) to justify the decision below.

The question presented is whether the Second Amendment permits a state to criminalize the possession of any ready-to-use firearm in all public parks by imposing felony penalties, including two to five years in prison, on violators.

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Commission for Lawyer Discipline (CLD) has alleged such

conviction requires mandatory disbarment under Texas Law (without

a meaningful opportunity to be heard in any forum). This

practice in Texas of denying an opportunity to be heard prior to

the imposition of collateral consequences violates this Court’s

teaching in Boddie v. Connecticut, 401 U.S. 371, 377-79 (1971);

Selling v. Radford, 243 U.S. 46, 51 (1917) and Padilla v.

Kentucky, 559 U.S. 356, 176 L.Ed.2d 284, 293 (2010) among others

and this Court’s guidance is required as follows:

I. The question for this Court is whether the due process clause of the United States Constitution (U.S. CONST. AMENDS. V; XIV) as explained in Boddie v. Connecticut, 401 U.S. 371, 377-79 (1971) requires notice and an opportunity to be heard before the imposition of collateral consequences (here disbarment)? |

Il. The question for this Court is whether the minimum Due Process afforded in attorney compulsory discipline cases is that which is described in selling v. Radford, 243 U.S. 46, SL (1917)?

III. The question for this Court is whether the Court’s holding in Padilla v. Kentucky, 559 U.S. 356, 176 L.Ed.2d 284, 293, 130 S.Ct. 1473 (2010) requires an opportunity to be heard under Strickland v. Washington, 466 U.S. 668, 689 (1984) prior to collateral consequences (here disbarment)?

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1. Whether Stinson v. United States, 508 U.S. 36 (1998), still accurately states the level of deference due to the commentary of the Federal Sentencing Guidelines. This is the question on which this Court eranted certiorari in Beaird v. United States, No. 25-5348.

2. Whether U.S.8.G. §2B1.1’s_ reference to “loss’—undefined in the Guideline text governing pe- titioner’s sentencing—may be read through Applica- tion Note 38(A) to include “intended loss” the defen- dant never realized.

Law Office of Gene Vorobyov Respectfully submitted, Attorney for Petitioner RUSLAN KIRILYUK

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1. Whether permanent disarmament under 18 U.S.C. § 922(g)(4), based solely upon prior temporary involuntary commitment to a mental institution (as opposed to being a “mental defective” — 1.e. during a current episode of mental illness, or incident to an adjudication of incompetence, or insanity), facially violates the Second Amendment under New York Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1, 142 S. Ct. 2111 (2022),

2. Whether for purposes of establishing a “relevantly similar” historical analogue under Bruen’s step two, there are objective limits on the scope of “how” and “why” the compared regulations burden the Second Amendment right — such that categorial disarmament using a completely open-ended and overbroad “dangerousness’ principle is entirely too generalized to use as part of Bruen’s analogical analysis.

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