This case presents an important question of federal bankruptcy law that has squarely divided the lower courts.

In the proceedings below, the en bane Ninth Circuit, siding with three circuits, held that a Chapter 7 trustee can be sued in her personal capacity for simple negli- gence. Unlike the Ninth Circuit (and its three companion circuits), four other circuits limit personal-capacity suits to “willful and deliberate” misconduct. And unlike both competing factions, the Fifth Circuit has staked out yet a third intermediate position—requiring a showing of “oross negligence” before a Chapter 7 trustee is person- ally liable.

The decision below solidifies this three-way conflict. It involves a critical question that affects thousands of bank- ruptcies nationwide, and this is the perfect opportunity for the Court to impose a uniform rule in an area generat- ing needless waste, inefficiency, and confusion.

The question presented is:

Whether Chapter 7 trustees may be personally liable for their official acts, and if so, under what standard liabil- ity is permitted.

(I)

To protect American industry, Congress has eranted the ITC the power to ban the importation of ar- ticles that infringe a patent. The statutory threshold for exercising this power is the patentee must show a “do- mestic industry” in articles protected by the patent.

The Federal Circuit has lowered the bar to meet that requirement. Here, it affirmed—based on a ra- tionale the agency never provided—a ban on Apple Watches with pulse oximetry to protect a patentee that barely sold a consumer product that used the patents. In so doing, the court held the patentee could show “signif- icant employment of labor or capital” under 19 U.S.C. §1337(a)(3)(B) by pointing to nascent R&D investments, even though R&D is_ expressly covered by §13837(a)(3)(C). The effect was to subject the R&D in- vestments to less rigorous scrutiny than is required by §1837(a)(38)(C). Because few ITC cases result in an ap- pellate decision, this case is arare opportunity to resolve the scope of Subparagraph (B), which even the ITC has called an issue of exceptional importance.

The questions presented are:

1. Whether a patentee fails to establish “significant em- ployment of labor or capital” “with respect to the articles protected by the patent” under 19 U.S.C. §1337(a)(8)(B) where the patentee’s investment falls into one of three uses listed only in §1337(a)(8)(C).
2. Whether the Federal Circuit’s affirmance of an agency decision where (1) the court’s rationale does not appear in the agency’s opinion and (2) the agency’s result was not re- quired by law is contrary to SEC v. Chenery Corp., 318 U.S. 80 (1943), and its progeny.

(i)

In General Motors Corp. v. Tracy, 519 U.S. 278 (1997), this Court held that a state-law exemption for in-state businesses did not implicate the dormant Com- merce Clause because the favored businesses and the disfavored ones sold “different products” and “servel[d] different markets.” Jd. at 298-299. The Fifth and Sixth Circuits have since confined Tracy to laws that distin- guish between entities competing in “different retail markets.” NextHra Energy Capital Holdings, Inc. v. Lake, 48 F.4th 306, 319 (Sth Cir. 2022); see Energy Michigan, Inc. v. Michigan Public Service Comm’n, 126 F .4th 476, 493 (6th Cir. 2025).

Below, a divided Ninth Circuit rejected the Fifth and Sixth Circuits’ focus on whether the regulated party “produces the same product * * * for in-state and out- of-state consumers.” App., infra, lla. The court in- stead read Tracy to immunize Washington’s cap-and- trade system, which requires utilities to buy allowances for greenhouse-gas emissions when generating exported electricity but awards free allowances for electricity sold to Washington retail customers—even though re- tail electricity is “the same product sold across multiple geographic markets.” /d. at 42a (Bress, J., dissenting). The question presented is:

Whether Tracy exempts a State from dormant Com- merce Clause scrutiny when state law imposes different burdens on the same product based on whether the product is sold in state or out of state.

(I)

This case concerns a money laundering offense in which Petitioner returned all of the money involved, with interest, and no one suffered any harm—financial or otherwise. Petitioner kept nothing, made no pro- ceeds, and was financially unable to pay a fine. After the district court declined to enter a forfeiture judg- ment, however, the Eleventh Circuit required the dis- trict court to authorize forfeiting the total amount of money involved in the transactions—ultimately re- sulting in a forfeiture money judgment of more than $10 million dollars in unspecified, untainted property. Breaking from its sister circuits and precedent, the Eleventh Circuit found no constitutional or statutory impediment to that result.

The questions presented are:

(1) Whether, in determining whether a fine contra- venes the Excessive Fines Clause, courts may consider the gravity of the underlying offense purely in the ab- stract or should consider the gravity of the specific de- fendant’s wrongdoing. This is the same question on which the Court granted certiorar1 in Jouppi v. State of Alaska, No. 25-246.

(2) Whether, in determining whether a fine contra- venes the Excessive Fines Clause, courts may 1gnore the financial status of the defendant.

(3) Whether, under 18 U.S.C. § 982(a)(1), the govern- ment can obtain a forfeiture money judgment for un- tainted substitute property in the amount of the full value of funds that changed hands during an offense, even if none of the forfeited property was tainted, the defendant never personally received anything, and the full amount was returned to the rightful owner before indictment.

(1)

Section 101 of the Patent Act, 35 U.S.C. § 101, pro- vides that “any new and useful process, machine, manufacture or composition of matter” 1s eligible for patenting. That provision is subject to a judicial ex- ception that excludes “laws of nature, natural phe- nomena, and abstract ideas.” Alice Corp. Pty. Ltd. v. CLS Bank Intl, 573 U.S. 208, 217 (2014). The Federal Circuit held Innovaport’s patent claims, which involve responding to a product location inquiry by providing the location of the product with additional relevant in- formation that was not the subject of the inquiry, are unpatentable as an abstract idea.

In doing so, the Federal Circuit (i) failed to attrib- ute any weight to the United States Patent and Trade- mark Office’s (“USPTO’s’) findings regarding eligibil- ity under § 101 notwithstanding the presumption of validity accorded to patents under 35 U.S.C. § 282 (11) did not consider the doctrine of preemption, 1.e., whether the claimed invention would preempt an en- tire field and therefore grant a monopoly over an ab- stract idea; (111) found that Innovaport’s patent claims were ineligible for patenting particularly because the patent claims did not recite fundamental or technolog- ical improvements to computer capabilities or func- tionality; and (iv) made factual findings without citing to record evidence.

The questions presented are:

1. Whether a court can disregard the USPTO’s el- igibility findings under 35 U.S.C. § 101?

The Constitution of the United States does not merely authorize the exercise of governmental power; it restrains that power. The Fourth Amendment protects the people against unreasonable searches and seizures, and the Fourteenth Amendment prohibits a State from depriving any person of property without due process of law. Those constitutional guarantees do not expire once the government acquires possession of private property. Rather, they continue to govern every exercise of governmental authority from the inception of an investigation through the permanent deprivation of private property by civil forfeiture.

This case presents recurring and exceptionally important questions concerning the continuing application of the Fourth and Fourteenth Amendments to state civil forfeiture proceedings.

The questions presented are:

Whether the Fourth Amendment’s prohibition against unreasonable searches and seizures continues to restrain governmental authority throughout the investigation, search, seizure, continued retention, examination, and permanent forfeiture of private property in a state civil forfeiture proceeding.

Whether the Due Process Clause of the Fourteenth Amendment permits a State to permanently deprive a citizen of private property without first providing meaningful judicial consideration of preserved federal constitutional objections concerning the legality of the governmental conduct upon which the forfeiture is based.

Whether a State may constitutionally acquire permanent title to private property where the forfeiture judgment rests upon governmental conduct

1

The questions presented are:

1. Whether Arizona Supreme Court Rule 34 — which categorically denies bar admission on motion to attorneys licensed and in good standing in eleven nonreciprocal states and denies recent graduates of law schools not accredited by the American Bar Association even the opportunity to sit for the Arizona bar examination, based on class membership rather than individual merit — violates the First and Fourteenth Amendments.

2. Whether Rule 34’s categorical class-based exclusions can survive any standard of review when Arizona extends automatic license reciprocity to every other profession regardless of home-state reciprocity, and 50 U.S.C. § 4025a mandates recognition of the very attorney licenses Rule 34 refuses to recognize.

Whether the territorial limits on state courts’ power embodied in the Due Process Clause, the Com- merce Clause, and principles of federalism prohibit a state-court receiver from controlling the litigation de- cisions and other internal affairs of an out-of-state corporation when the receiver has not been recognized in the corporation’s place of incorporation.

This case concerns the central issue of whether Antonio Goodwin was employed by AT&T, AT&T Mobility LLC, AT&T Inc., AT&T Corp., or any AT&T-related entities/Companies.

WHY THE FIFTH AMENDMENTOFTHE CONSTITUTION, THE DUE PROCESS CLAUSE, WAS VIOLATED BY JUDGE DANIEL J. ALBREGTS, GLORIA NAVARRO, FRIEDLAND, NELSON, AND BADE.THE 63 INTERNAL AUTHENTIC AT&T EMPLOYMENT DOCUMENTS PROVE BEYOND AN REASONABLE DOUBT MR ANTONIO GOODWIN WAS AN EMPLOYEE OF AT&T,SENT DIRETLY FROM AT&T CORPORATE OFFICE TO THE EEOC. ON JANUARY 3, 2023

Why The Fifth Amendment Due Process Clause was violated by Judge Daniel J. Albregts, Gloria Navarro, Friedland, Nelson, and Bade regarding Mr. Antonio Goodwin filing sanctions against AT&T on Document 51 and 54 on April 10, 2025, against AT&T, Pamela M. Phillips, and Stacey Campbell for making false employment statements under oath by stating Mr. Antonio Goodwin was never an employee of any AT&T companies.

The Judges did not take any of Mr. Antonio Goodwin’s evidence into consideration, as well as ignored Mr. Antonio Goodwin’s 900 authentic AT&T employment documents in front of Judge Daniel J. Albregts, Judge Gloria Navarro, Judges Friedland, Nelson, and Bade. The Judges violated the Fifth Amendment Due Process Clause.

Mr. Antonio Goodwin’s 900 authentic AT&T employment documents were filed 3 months before the Rule 11 sanctions were filed against Mr. Antonio Goodwin on June 5, 2025. The Judges ignored Mr. Antonio Goodwin’s 900 authentic AT&T employment documents from April 10, 2025, through March 31, 2026, and through the June 2, 2026 Order. Furthermore, from September 10, 2025, through June 2, 2026, Mr. Antonio Goodwin’s dispositive motion consisting of 1,053 AT&T employment documents and 5,000.00 AT&T employee images was never ruled on, which was filed on September 10, 2025, under ECF Nos. 131, 134, and 136, ECF Nos. 155 and 156, ECF No. 174, and ECF No. 199. Furthermore, Antonio Goodwin’s 63 authentic AT&T employee documents were sent directly from AT&T Corporate Office to the EEOC on January 3, 2023, which was filed before any sanction was granted on December 30, 2025, regarding Mr. Antonio Goodwin’s AT&T employment with AT&T.

In civil litigation, this is an absolutely serious violation of the Fifth Amendment Due Process Clause.

2. WHY THE FIFTH AMENDMENT OF THE CONSTITUTION WAS VIOLATED REGRADING THE MOTION TO RECALL THE MANDATE IN THE NINTH CIRCUIT COURT FILED ON JUNE 9, 2026 BASED ON THE EXISTING DISCOVERED JANUARY 3, 2023 63 AUTHENTIC AT&T EMPLOYEE DOCUMENTS SENT DIRECTLY FROM AT&T CORPORATE OFFICE TO THE EEOC IN THE LAWSUIT AGAINST AT&T. WHICH THE 63 AUTHENTIC AT&T EMPLOYMENT DOCUMENTS PROVE BEYOND AN REASONABLE DOUBT MR ANTONIO GOODWIN WAS AN EMPLOYEE OF AT&T, THIS WAS A MATERIAL CONTRADICTION OF AT&T & PAMELA

M. PHILLIPS’ DECLARATION, AT&T/ PAMELA M. PHILLIPS QUOTE “THERE ARE NO RECORDS OF MR ANTONIO GOODWIN EVER BEING AN EMPLOYEE OF ANY AT&T COMPANIES. WHICH IS A SERIOUS VIOLATION OF THE FIFTH AMENDMENT DUE PROCESS CLAUSE BY THE JUDGES., ALSO SANCTIONS WAS WRONGFULLY IMPOSED ON MR GOODWIN BY MAGISTRATE JUDGE DANIEL J. ALBREGTS AND DISTRICT JUDGE GLORIA M. NAVARRO, FOR MR ANTONIO GOODWIN STATING HE WAS AN AT&T EMPLOYEE AND MR GOODWIN STATING AT&T/STACEY CAMPBELL COMMITTED PERJURY/FRAUD ON DOCUMENT 54 AND 51. WHICH MR ANTONIO GOODWIN FILED 900 AUTHENTIC AT&T EMPLOYMENT DOCUMENTS SUPPORTING CLAIMS AGAINST AT&T/STACEY CAMPBELL. ALSO MR ANTONIO GOODWN WAS WRONGFULLY SANCTION FOR MISSING A IN PERSON DEPOSITION HELD ON SEPTEMBER 25, 2025

five claims by filing an amended complaint by a date certain. Petitioner timely complied. Respondents nevertheless submitted a proposed order stating the opposite and dismissing multiple claims with prejudice. Before entry, Petitioner filed the transcript and formally objected that the proposed order misstated the court’s ruling. The order was nevertheless entered and remains uncorrected, although Respondents later acknowledged in a filed motion that it contradicted the ruling. The question presented 1s:

Whether the Due Process Clause permits a State to leave in force—and

require a litigant to proceed under—a facially preclusive order that

contradicts the court’s recorded ruling, after the litigant timely satisfied

the court’s express condition for preserving his causes of action and

proved the contradiction before entry.

1

Petitioner’s guilt was established by two pieces of constitutionally dubious evidence.

First, the Commonwealth was allowed to offer a Bruton-ized summary of Petitioner’s

statement stating that Petitioner confessed to the only disputed fact. Petitioner

disputed the accuracy of that summary, however he was unable to offer the full text of the statement to give the jury a chance to determine what he meant. Second, the

Commonwealth relied on out of court Spanish to English translations of text

messages, the accuracy of which was disputed. The translations were prepared by a

police officer in anticipation of trial, but introduced by a different officer who spoke

no Spanish and could not be examined on the original meaning of the messages.

The Kentucky Supreme Court affirmed both rulings, giving rise to the following

important questions:

I. Whether a defendant’s statement to police can be rewritten to comply with Bruton v. United States, 391 U.S. 123 (1968)? If so, are there limits to the extent to which a statement may be altered to meet Bruton requirements? If the defense disputes that the rewritten statement accurately presents what the defendant said, is it sufficient that the defendant was allowed to cross- examine the police witness without specifically describing the statement or must the defendant be permitted to present the full text of the statement to enable the jury to resolve the dispute?

Il. Whether, under Crawford v. Washington, 541 U.S. 86 (2004), the Confrontation Clause applies to a police interpreter’s out of court translation of a written statement, created for later use at trial?!

1 This Question is also presented in the petition filed by co-defendant Mario Tzunux-

Zacarias.

ia

reference to a motion-in-limine that unhinged defense counsel. A

few hours later in a sealed bench conference (sealed from

Martinez and the jury) the AUSA and defense counsel collectively

sought to pause trial to explore plea negotiations. This action

was unknown to and unauthorized by Martinez. The court, to induce and assist defense counsel in coercing a plea from Martinez, offered “a sweetener’ to defense counsel in violation of Fed. R. Crim. Proc. Rule ll(e). In response, the United

States confessed that the court’s practice of offering

“sweeteners” to coerce pleas from defendants was a long standing

practice and procedure of the court and well known to counsel who

practice before the United States District Court in San Antonio,

Texas. Martinez filed a motion to recuse based on this and other

irregularities in the court’s procedural conduct.

I. The question for this Court is whether a trial court’s long held practice of offering ““sweeteners’’ to induce defense counsel to coerce their clients into pleading guilty meets the Liteky v. United States, 510 U.S. 540 (1994) “extrajudicial source” standard applied by this Court requiring recusal under 28 U.S.C. §455(a)?

Il. The question for this Court is whether a court’s long held practice of offering ‘sweeteners’’ to induce defense counsel to coerce their clients into pleading guilty is structural error as explained in Tumey v. Ohio, 273 U.S. 510, 535 (1927) (no matter the evidence, there is the right to have

-i- .