Does a defendant have a right to a jury trialina misdemeanor domestic violence offense where the penalty carries up to six months in jail, a $1,000.00 fine, loss of all Second Amendment rights under federal law, loss of Second Amendment rights under state law, and can never be expunged?

REASONS FOR GRANTING THE WRIT

|. This Case Presents an Important Federal Question on the Treatment of Pro Se Civil Rights

Claims

This case presents a recurring and important federal question: whether lower courts may

dismiss pro se civil rights complaints without meaningfully addressing the underlying |

constitutional violations. wi , Petitioner brought claims under 42 U.S.C. § 1983 alleging violations of federally protected

rights. The lower courts resolved the case solely on procedural grounds, without substantive

engagement with those constitutional claims. This approach raises serious concerns regarding

the integrity of judicial review and the enforcement of constitutional protections.

Il. The Decision Below Conflicts with This Court’s Precedent Requiring Liberal Construction of

Pro Se Pleadings

This Court has repeatedly emphasized that pro se pleadings must be liberally construed and

that dismissal without leave to amend is disfavored unless amendment would clearly be futile.

Here, the district court dismissed Petitioner’s complaint without providing a meaningful }

opportunity to amend and without fully analyzing the factual allegations presented. The court’s

conclusion of futility was conclusory and deprived Petitioner of a fair opportunity to present his.

claims. ,

The Fourth Circuit’s affirmance reinforces this departure from established principles and

warrants this Court’s review.

Ill. The Case Implicates the Fundamental Right of Access to the Courts

The Constitution guarantees meaningful access to the courts. When courts dismiss claims |

without addressing their substance, particularly in cases involving pro se litigants alleging

constitutional violations, that guarantee is undermined.

This case reflects a broader systemic issue in which procedural barriers prevent substantive

justice. Review by this Court is necessary to ensure that constitutional claims receive

meaningful consideration.

CONCLUSION | nS

For the foregoing reasons, the petition for a writ of certiorari should be granted. :

Respectfully submitted,

King Miguel Eddie Crayton

Pro Se Petitioner

APPENDIX

Appendix A

United States Court of Appeals for the Fourth Circuit Opinion (September 22, 2025)

Appendix B

United States District Court Final Order (July 2, 2025)

Appendix C

District Court Order (January 27, 2025) 4S

Appendix D Court proceedings.

CERTIFICATE OF SERVICE

(A) Has the Fifth Circuit entered a decision in “CONFLICT” with her sister circuits and lower federal courts, on the same important issues, of wheather A.E.D.P.A.’s successive petition rules apply to “BRADY” and “NAPUE”” violations that were “NOT RIPE” at the time of the initial petition, based on “NEWLY DISCOVERED” DNA forensic test evidence; |

(B) Has the Fifth Circuit entered a ruling that ““CONTRAVENS” United States Supreme Court “PRECEDENT” set in Panetti V. Quarterman, on wheather A.E.D.P.A.’s successive petition rules apply to violations that were “NOT RIPE™ at the time of the initial habeas petition, based on “BRADY” and “NAPUE” violations shown by NEWLY DISCOVERED FORENSIC DNA TEST EVIDENCE;

(C) Has the Fifth Circuit entered a decision in ““CONFLICTI” with its sister circuits and lower federal courts, on the same “IMPORTANT ISSUES” of wheather A.E.D.P.A.’s successive petition rules apply

to § 60 (b), § 60 (d) (3), “FRAUD UPON THE COURT” violations that demonstrate EGREGIOUS, “intentionally fraudulent conduct directed at state and federal courts; |

(D) Has the Fifth Circuit entered a ruling that “CONTRAVENS™ United States Supreme Court “PRECEDENT™ on wheather A.E.D.P.A.’s successive petition rules apply to § 60 (b), § 60 (d) (3), “FRAUD UPON THE COURT” where state officers of the court of Texas, did DILIBERATELY PLAN AND EXCUTE A SCHEME TO DEFRAUD STATE AND FEDERAL COURTS. ,

I.

1. Whether the legal test examining the transactional nucleus of facts shared between causes of action, which evolved as common law of “res judicata doctrine” for the purpose of estoppel, is unconstitutional.

2. Whether the court of appeals may not take for review on the merits and grant a motion for summary disposition at “any time” during prolonged extension of time given for filing the answering brief. |

3. Whether the court of appeals erred in affirming, based on “insubstantial appeal” standard, the district court dismissal of the Petitioner’s complaint.