1.Whether a federal district court, exercising federal-question jurisdiction over claims under 42 U.S.C. § 1983, may enter summary judgment dismissing those claims with prejudice on qualified-immunity grounds where the plaintiff alleges and supports with record evidence that officers entered and searched before issuance of a warrant, that the warrant affidavit contained materially false or misleading facts, and that the affiant later made statements arguably undermining the asserted factual nexus to the place searched.

2.Whether the Tenth Circuit’s application of ’arguable probable cause’ conflicts with Franks v. Delaware, 438 U.S. 154 (1978), Malley v. Briggs, 475 U.S. 335 (1986), and Groh v. Ramirez, 540 U.S. 551 (2004), when it treated issuance of a

| warrant and judicial disagreement as supporting immunity without resolving evidence of a pre-warrant search or alleged knowing or reckless material falsehoods.

3. Whether the Fourteenth Amendment permits a state court to extinguish with prejudice claims arising from an asserted unconstitutional search and seizure without meaningful consideration of the litigant’s continuation, tolling, and due- process contentions, where the procedural history was shaped by removal and remand and where the underlying claims had repeatedly been pursued rather than abandoned.

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4. Whether the Decision Below Conflicts with This Court’s Precedents on Access to Courts and the Liberal Construction of Pro Se Filings.

5. Whether a pro se civil rights plaintiff demonstrates “extraordinary circumstances” under Federal Rule of Civil Procedure 60(b)(6) sufficient to justify reopening a final judgment when, for a two-month period critical to post-judgment deadlines, she was illegally, unlawfully and unconstitutionally imprisoned by the defendants themselves and held in a jail cell for nearly two weeks without any means to access the courts,

| including being denied mail, telephone, and writing materials.

3. Whether a court of appeals errs by applying a strict forfeiture rule to a pro se litigant who focuses her appellate brief on the merits of the underlying dismissal rather than the procedural denial of her post-judgment motion, particularly when the basis for the post-judgment motion—unconstitutional interference with her right of access to the courts—is inextricably intertwined with the substantive claims against the defendants.

4. Whether the continuing violations doctrine applies to toll the tme for filing a post- judgment motion where state actors, who are the defendants in the underlying § 1983 _ action, commit new, related constitutional violations (false imprisonment and denial of access to the courts) after judgment has entered, and where the related criminal case against the petitioner was not terminated in her favor until November 24, 2025 after the appeal was decided.

QUESTIONS PRESENTED )

1. Whether the Sixth Circuit’s decision upholding Ohio’s automatic driver’s license suspension scheme under R.C. §§ 3123.55(A), 3123.58, and 3123.60—which mandates suspension without pre-deprivation notice or hearing and

expressly prohibits the state agency from granting any appeal—conflicts with this Court’s holding in Bell v. Burson, 402 U.S. 535 (1971), and deepens an explicit Circuit split with the Fourth Circuit’s en banc decision in

2. Stinnie v. Holcomb, 55 F.4th 951 (4th Cir. 2022).

3. Whether the lower courts erred in dismissing Petitioner’s claims WITH PREJUDICE on procedural and immunity grounds, where the dismissal permanently forecloses all judicial remedies under principles of res judicata and claim preclusion, despite written, sworn admissions by state respondents that the underlying suspension was factually baseless and executed without due process. |

4. Whether a state motor vehicle agency is immune from suit under the Eleventh Amendment when enforcing a concededly unconstitutional statutory scheme, where the agency’s own sworn admissions establish that it suspends licenses prior to notice through a purely mechanical, non- discretionary act. _ |

5. Whether a district court’s blanket, non-individualized certification under 28 U.S.C. § 1915(a)(3) across multiple actions by an indigent pro se litigant conflicts with Coppedge v. United States, 369 U.S. 438 (1962), and violates Griffin v. Hlinois, 351 U.S. 12 (1956), and M.L.B.

| v.S.L.J., 519 U.S. 102 (1996), by creating an impenetrable procedural barrier to appellate review.

The questions presented are:

Whether a federal court of appeals may affirm a criminal conviction under 18 U.S.C. §§111 and 1114 by invoking an uncharged “person assisting” protected- person theory where the indictment charged assault on a federal officer, the jury was not instructed on the alternative theory, the government relied on generalized testimony that a local task-force officer was “special deputized,” and petitioner preserved a Rule 29 challenge to the absence of oath, deputation, MOU, renewal, expiration, United States Attorney approval, or other competent federal-status documentation, in conflict with United States v. Washington, 79 F.4th 320, 327-31 (3d Cir. 2023), and United States v. Torres, 862 F.2d 1025, 1030 (3d Cir. 1988)?

Whether affirming a conviction on an uncharged statutory theory violates the Fifth and Sixth Amendments, including United States v. Gaudin, 515 U.S. 506, 510- 15 (1995), and Stirone v. United States, 361 U.S. 212, 217-19 (1960), where the substitute theory was never charged by the grand jury, never submitted to the petit jury, never found beyond a reasonable doubt, and disputed element facts were treated as established through counsel concessions, a warrant stipulation, or a Fed. R. Evid. 201 posture despite petitioner’s express pretrial objections?

Whether due process and 28 U.S.C. §455(a) permit a federal district judge who recused from a related civil rights action arising from the same operative facts

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1. Whether Stinson v. United States, 508 U.S. 36 (1998), still correctly states the rule for the deference that courts must give the commentary to the Sentencing Guidelines.

2. Whether, under the version of USSG § 2B1.1(b)(1) 1n effect before November 1, 2024, the term “loss” includes intended loss, or instead means only actual loss.

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Since the Court issued its ruling in New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022), frontline defense lawyers and prosecutors, along with district courts and courts of appeals, have grappled with how the holding applies to 18 U.S.C. § 922(g)(1). Is the statute facially invalid? Is it subject to as-applied challenge? If so, how does that challenge work? Criminal defense lawyers and prosecutors have spent hours upon hours litigating these issues. District courts and appellate courts have expended massive amounts of time and energy ruling on these issues. Defense lawyers cannot stop raising the issue because this Court has not given us any final answers. Without answers from this Court, defense lawyers cannot tell clients that challenging the constitutionality of § 922(¢)(1) 1s frivolous, even if the applicable court of appeals has rejected the argument. So, we must keep filing motions and briefs. We are stuck 1n purgatory, or ground hog day, or whatever metaphor strikes your fancy.

Perhaps the Court needed to flesh out Bruen on lesser used subsections of § 922(g¢g) before tackling subsection (g)(1). See United States v. Rahimi, 602 U.S. 680 (2024) (§ 922(¢)(8)); United States v. Hemani, 146 8. Ct 1677 (2026) (§ 922(¢)(8)). That’s understandable. But the time has come. We need an answer on § 922(g)(1) and we need it now.

The Question Presented 1s:

Whether 18 U.S.C. § 922(g)(1), the federal statute that prohibits anyone who has been convicted of “a crime punishable by imprisonment for a term exceeding one year” from possessing a 1

This case concerns the propriety of a District Court applying a four-level enhancement under what is, today, U.8.8.G. § 2K2.1(b)(7)(B). That enhancement applies when a defendant possesses a firearm in furtherance of any other felony offenses. It was undisputed that Mr. Mims committed the felony of Third-Degree Burglary, as defined by Oklahoma law, which involves breaking into and entering a vehicle with the intent to steal or commit some other crime therein. This crime does not satisfy the definition of generic burglary.

In breaking into a truck, Mr. Mims found and took a handgun and then left the area. Thus, Mr. Mims’s possession of a firearm in the course of any other felony occurred only in the sense that he found a firearm while committing that other felony and took it with him. The firearm was the fruit of a felonious act, but 1t played no other role in the offense. The Commentary to U.S.8S.G. § 2K2.1 specifically explains that the four-level enhancement applies to the discovery of, and taking of, a firearm during another felony when the other felony “is burglary.”

The Commentary is silent as to whether the discovery of, and taking of, a firearm will always satisfy the four-level enhancement, even when a defendant commits a felony other than generic burglary.

The question presented is: Does the plain language of the Commentary to U.S.8.G. § 2K2.1(b)(7)(B) limit certain applications of the four-level enhancement to when the other felony offense “is burglary”?

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I. Petitioner asks that the Court should hold this petition pending a decision in Beaird v. United States, No. 25-5348, and alternatively asks whether Stinson v. United States still correctly states the rule for deference that courts must give the commentary of the Federal Sentencing Guidelines?

II. Whether the Court should grant, vacate, and remand for reconsideration because of an intervening circuit decision that may invalidate precedent on which the panel opinion below relies.

III. May Congress criminalize intrastate firearm receipt based solely on the fact that the firearm crossed state lines at some indefinite point before the defendant re- ceived it?

IV. Whether 18 U.S.C. § 922(n) comports with the Second Amendment.

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