A suspect fled upon North Las Vegas police officers responding to a domestic violence call. Based on information known at the time, including visible injuries to the alleged victim, as well as the suspect’s history of violent crimes and outstanding arrest warrants, officers immediately set up a line-of-sight perimeter and called in a K-9 (police dog) unit to help locate the suspect. Upon the K-9 alerting to a scent approximately 18 minutes after the suspect fled, and based on the exigent circumstances, officers entered a backyard approximately four houses away from the victim’s residence. Three pitbull mix dogs emerged. Two of them attacked the K-9 and officer. The officer shot and killed the attacking pitbulls, and the pitbulls’ owners sued the City and two of its police officers. The United States Court of Appeals for the Ninth Circuit reversed the district court’s finding of qualified immunity on the plaintiffs’ Fourth Amendment unreasonable search claim based on a single, factually distinct circuit case. The questions presented are:

1. Whether the officers’ warrantless search of a backyard in close proximity to the domestic violence victim’s residence was a lawful “hot pursuit” when the suspect’s trail was temporarily lost within the perimeter for approximately eighteen minutes but recovered through immediate and continuous police efforts.

2. Whether, even if the search did not qualify as a “hot pursuit,” the officers were entitled to qualified immunity because no “clearly established law” was violated.

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1. Does 18 U.S.C. § 922(¢g)(1) violate the Second Amendment on its face or as applied to Petitioner?

2. Does 18 U.S.C. § 922(g)(1) exceed Congress’s authority under the Commerce Clause on its face or as applied to Petitioner’s intrastate possession of a firearm?

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1. Whether the Court should hold this petition pending its decision in Hunter v. United States, No. 24-1068, and dispose of it accordingly, where the Second Circuit dismissed the criminal appeal as barred by an appellate waiver deemed to waive “all challenges,” and failed to consider contractual defenses, claims of unconstitutional and structural error that placed convictions and sentences for unadmitted murder-for-hire crimes against a second unadmitted victim outside the scope of the appellate waiver, claims sentences exceeded statutory maximums, and failed to address the government’s breach by advocacy the defendant could be convicted and sentenced for unadmitted crimes it agreed to dismiss.

2. Whether the Court should hold this petition pending its decision in Hunter v. United States, No. 24-1063, and dispose of it accordingly, where the district court advised the defendant at sentencing of a far less restrictive appellate waiver than the plea agreement, or that applied by the Second Circuit, and the government did not object.

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The Fourth Amendment “draw|s] a firm line at the entrance’ to the home, which includes its curtilage. Payton v. New York, 445 U.S. 573, 590 (1980); see also Florida v. Jardines, 569 U.S. 1, 6 (2018). Absent “exigent circumstances,” a police officer cannot “enter a home or its curtilage in order to search a vehicle therein” without a warrant. Collins v. Virginia, 584 U.S. 586, 601 (2018). And “application of the exigent-circumstances exception in the context of a home entry should rarely be sanctioned when there is probable cause to believe that only a minor offense … has been committed.” Welsh v. Wisconsin, 466 U.S. 740, 753 (1984). Rather, the case-by- case inquiry requires that the “totality of circumstances shows an emergency.” Lange v. California, 594 U.S. 295, 308 (2021). The questions presented are:

1. Whether a portion of a driveway immediately adjacent to a home is curtilage under the Fourth Amendment.

2. Whether a parked car’s tinted windows categorically qualify as an exigent circumstance to justify an officer’s warrantless entry onto the home’s curtilage and search of the vehicle.

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conduct, without proof of ynkent to Laciliteake the crime.

2. Whether the admission of highly oredudicial gong evidence

Violates due process where vt renders the tria\ Fundamentally

Unfair under Estelle v. McGuire,502 US. 62 (aa):

3. whether the cumulative efsect of multiple trial errors

Can deny due process even where dividual exrors ore

deemed harmless. a |

UW Whether the Lower courts Misapplied the certificate ob Appeatability standard under slack v. McDamiel ane Miller-EL v. coche by denying aA Cet LSiceke of Appealabi lity despite debatable Constitutional clams. |