State’s two coastal counties in one district, allowing

one voice to represent the Gulf Coast in Congress. The

2021 Plan, which made minimal changes to its

predecessor, was preliminarily enjoined under §2 of

the Voting Rights Act for prioritizing the Gulf Coast over another community of interest, the Black Belt

(named for its rich soil). Rather than litigate the

lawfulness of the 2021 Plan, the State adopted the

2023 Plan, which kept both the Gulf Coast and Black

Belt intact to the fullest extent possible. It also

furthered the lLegislature’s goal of protecting

incumbents. Still, the district court enjoined use of the

2023 Plan, deemed the State’s political goals

“illegitimate,” and found that the State had

intentionally discriminated by failing to draw another

majority-minority district. The questions presented are:

1. Did the district court err by not requiring Plaintiffs to offer an alternative map that performed just as well as the State’s map with respect to the State’s districting criteria?

2. Did the district court err by finding racial-bloc voting without accounting for politics?

3. Did the district court err by finding that the totality of circumstances suggests an objective likelihood of discrimination?

4. Did the State violate the Fourteenth Amendment by declining to draw a race-based plan?

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?

1

QUESTIONS PRESENTED FOR REVIEW ISSUE 1: The district court erred in denying petitioner’s motion for judgment of acquittal as to count 1 felon in possession of a firearm-and or; the evidence was insufficient to sustain the guilty verdict as to count 1; where the trial evidence failed to prove knowing possession of a firearm by petitioner on April 12, 2023 or April 20, 2023. ISSUE 2: The district court erred in denying petitioner’s objection to the PSI Report inclusion of the reference and evidence of the uncharged-unproved shooting on April 15, 2023 where no evidence was presented at trial and no witnesses identified petitioner as the shooter and evidence of gang membership. ISSUE 3: The district court erred in denying petitioner’s motion for downward variance grounded upon his disadvantaged upbringing and mental health issues. ISSUE 4: The district court erred in granting the government’s motion for upward variance grounded upon petitioner’s overstated criminal history, the April 15, 2023 uncharged shooting unproven gang membership and unwarranted sentencing disparity. ISSUE 5: The district court erred in denying petitioner’s motion to exclude evidence of victim injury photos and