After the Friendswood officials tried to shut down his lawfully opened restaurant during the COVID-19 pandemic, Petitioner Fred Rahdar publicly criticized the chief of police with a billboard labeling him as a bully and created a website and public petition calling for his removal. In _ response, Defendants designed and executed a multi-year retaliation campaign against Petitioners, which included harassment, surveillance, multiple arrests, complaints to the Texas Alcoholic Beverage Commission, daily bar checks for his restaurant, highly irregular arrest procedures, and a fifth arrest for a nonviolent misdemeanor based on a statute that has never before (or since) been used to charge someone for the same or similar conduct.

The question presented 1s:

1. Whether the opinion in Gonzalez v.

Trevino, 144 S. Ct. 1663 (2024), authorizes the

use of any objective evidence to defeat probable

cause.

The question presented in this case is the same as the one this Court granted certiorari to resolve in Lab’y Corp. of Am. Holdings v. Davis, 145 8. Ct. 11388 (2025):

Whether a federal court may certify a class action pursuant to Federal Rule of Civil Procedure 23(b)(3) when some members of the proposed class lack any Article III injury.

The § 3A1.4 terrorism sentencing guideline enhancement incorporates the statutory definition for a “Federal crime of terrorism[.]” U.S.S.G. § 3A1.4, Application Note 1. Title 18 U.S.C. § 2332b(g)(5)(A)’s definition of a “Federal Crime of Terrorism” refers to “an offense that … is calculated to influence or affect the conduct of government by intimidation or coercion, or to retaliate against government conduct.” Neither “government” nor “calculated” is defined.

After the President derecognized the Bashar al-Assad regime as the legitimate government of Syria, Mirsad Ramic left the United States, joined ISIS, and fought in the Syrian civil war. A federal jury later convicted him of terrorism- related offenses, and the District Court applied the § 3A1.4 terrorism sentencing enhancement, a decision that a Sixth Circuit panel affirmed.

The questions presented are:

I. Whether a foreign regime that the President of the United States has derecognized as a government is a “sovernment” under the definition for a “Federal crime of terrorism’”?

II. Whether leaving the United States, joining ISIS, and fighting in the Syrian civil war is conduct that 1s “calculated” to influence or affect the United States under the definition for a “Federal crime of terrorism’”?

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Bryan Vannausdle pled guilty to one count of receipt of child pornography, based upon images and videos he received from Minor Victim 1 (“MV1”). The district court applied a four-level enhancement under USSG §2G2.1(b)(4)(A) to Mr. Vannausdle’s advisory Guidelines range because the material allegedly portrayed “sadistic or masochistic conduct or other depictions of violence.” The basis for the enhancement was images and videos where MV1, a _ postpubescent female, masturbated by self-inserting a dildo.

The Eighth Circuit upheld this application, and in doing so, confirmed a per se application of the enhancement anytime the material involves self-penetration of a minor, no matter the specific facts or circumstances of the case. This holding conflicts with the holdings of all other Circuits to address the issue. Mr. Vannausdle’s petition asks the Court to address:

Whether USSG §2G2.1(b)(4)(A) can be applied per se anytime material

involves self-penetration of a minor, or if it must be applied on a case-

by-case basis, after an objective inquiry. ia

1. Where a state court finds there is no prejudice under Strickland v. Washington, 466 U.S. 668 (1984) from defense counsel’s failure to present allegedly cumulative evidence of a capital defendant’s mental illness, is that state court adjudication factually unreasonable under 28 U.S.C. §2254(d)(2) where the trial evidence depicted the petitioner as a malingerer of mental illness, and the omitted evidence demonstrated the petitioner had suffered from a genuine and severe mental illness?

2. Under de novo review, 1s defense counsel’s performance deficient under Strickland v. Washington, 466 U.S. 668 (1984) where counsel fails to present mitigation evidence of a capital defendant’s severe mental illness that was readily available to counsel in the defendant’s prison records, and counsel was put on notice that those prison records were material to the defendant’s mitigation case?

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