Did the trial court abuse its discretion and violate Due Process by imposing a $2,000 fine against the Plaintiff for filing his amended Answer 2 days late.

| When the Plaintiff was unable to pay the fine the Court imposed a second fine of $2,000 and then dismissed the case for failing to pay $4,000 in fines within 10 days.

1. Whether a court may refuse to apply United States v. Cronic, 466 U.S. 648 (1984), under 28 U.S.C. § 2254(d) absent a prior Supreme Court case involving materially identical facts, even where counsel disclaimed representation, failed to prepare or investigate, and entirely failed to subject the prosecution’s case to meaningful adversarial testing at a critical stage?

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Federal law bans the possession of firearms by anyone who has ever been convicted of a crime punishable by more than one year of imprisonment. 18 U.S.C. § 922(¢)(1). What rule(s) should the lower courts apply when evaluating whether a prosecution or conviction under that statute 1s consistent with the Second Amendment to the Constitution?

Under the prevailing interpretation of the nexus-with-commerce element of 18 U.S.C. § 922(g)(1), a former felon possesses “in or affecting commerce’ a firearm if the firearm was made in another state or country. Does Congress have the constitutional authority to enact such a law?

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I. Whether 18 U.S.C. §922(¢)(1) comports with the Second Amendment?

Il. Whether 18 U.S.C. §922(¢g) permits conviction for the possession of any firearm that has ever crossed state lines at any time in the indefinite past, and, if so, if it is facially unconstitutional?

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