process by dismissing her claims as frivolous and moot without an evidentiary hearing despite documentary evidence? 2. Whether dismissal as frivolous under 28 U.S.C. §1915 is proper where document evidence supports allegations of fraud, spoliation, and constitutional violations? 3. Whether the lower courts erred in finding the case moot despite continuing injury and hardship? 4, Whether dismissal without meaningful consideration of evidence violated the Fourth, Seventh, and Fourteenth Amendments? 5. Whether the exclusive jurisdiction of (FECA) and the (CSRA) bar federal courts from reviewing systemic fraud, malfeasance, and claim manipulation by federal agencies, or must the Supreme Court intervene to protect the civil rights of thousands of injured employees when the administrative system fails to provide an adequate remedy? 6. Whether the (CSRA) and (FECA) unconstitutionally strip courts of jurisdiction over Colorable First and Fifth Amendment claims brought by Forma Pauperis litigants, presenting an issue of National Importance concerning the Constitutional Rights of all Federal Employees?

In Brown v. United States, 602 U.S. 101 (2024), this Court held that whether a prior state drug trafficking conviction qualified as a predicate under the Armed Career Criminal Act in a federal prosecution required a review of the state conviction at the time of the conviction. However, this Court expressly left open the question of whether a federal sentencing court must review the state conviction at the time of the federal sentencing, rather than at the time of the conviction, for a recidivist enhancement under the United States Sentencing Guidelines given the requirement that the Sentencing Guidelines in effect at sentencing must be applied.

The First Question Presented here is:

Whether, consistent with federal statute mandating the application of the United States Sentencing Guidelines in effect at the time of sentencing, a sentencing court must look to the validity of a state prior at the time of federal sentencing to determine whether the state conviction qualifies as a predicate offense for a recidivist sentencing enhancement under the United States Sentencing Guidelines?

This Court recently granted a petition for a writ of certiorari on the question of “whether the Second and Fourteenth Amendments guarantee the right to possess AR-15 platform and similar semiautomatic rifles.” Viramontes v. Cook County, No. 25-238 (June 30, 2026), see also Grant v. Higgins, No. 25-566 (June 30, 2026). Mr. Coleman entered a plea of guilty to a charge of possession of an unregistered machinegun. Factually, Mr. Coleman was in possession of a small metal object known as a conversion device which allows an AR-15 semi-automatic assault rifle to fire ten shots with one pull of a trigger.

The Second Question Presented here is:

Whether the Second and Fourteenth Amendments guarantee the right to possess an AR-15 platform semiautomatic rifle outfitted with a conversion device or a conversion device which allows an AR-15 platform semiautomatic rifle to shoot ten times with a single pull of the trigger?

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The Second Circuit Court of Appeals erred, in violation of U.S. Const. V and Congress intent to provide a streamlined scheme of sentencing review established by the Sentencing Reform Act of 1984, when it denied Concepcion’s constitutional challenges to his condition of supervision as unripe on direct appeal. Its decision is also a departure from the majority view among Courts of Appeals’ decisions that have examined similar issues. This Court should grant certiorari to provide clarity about this reoccurring issue.

The Second Circuit also treats a sentencing argument supporting an otherwise preserved claim as an unpreserved, forfeited claim subject to waiver. The Second Circuit’s broad definition of issue waiver 1s incorrect and inconsistent with this Court’s jurisprudence. This Court should grant certiorari to bring the Second Circuit in line with this Court’s waiver jurisprudence.

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