William Henry Starrett, Jr. v. City of Richardson, Texas
SocialSecurity DueProcess Securities Privacy Jurisdiction JusticiabilityDoctri
Whether allegations are sufficient to support claims under 42 U.S.C. § 1983 and 42 U.S.C. §§ 1985(2)-(3)
QUESTIONS PRESENTED 1. Whether, in an initiating pleading or complaint, allegations are sufficient in the absence of . explicit facts as to the one or more official policies or customs corresponding to its claims : under 42 U.S.C. § 1983 and the specific manner and means of conspiracy controversial under 42 U.S.C. §§ 1985(2)-(8) that each provided cause to employees of a municipality and the federal government to act with outcome of injury. 2. Whether, for causes of action under federal law, a Texas municipality's liability arising from its police and fire protection and control is limited by the Texas Uniform Declaratory Judgments Act or the Texas Tort Claims Act, and, does such violate right to substantive due process under light of this Court's precedent and the Fourteenth Amendment to the Constitution of the United States of America. 3. Whether coordinating practices between municipality and state police department officials with federal investigative units could now be so permanent and well settled as to : constitute a custom or usage with the force of law for causes of action applicable to 42 U.S.C. § 1983. : 4. Whether a police department of a municipality acts as a civil authority to which military must ii remain subordinate to as directed under the Texas Constitution Article One Section 24 and ; either such relationship or the rights of crime victims enumerated under the Texas Constitution Article One Section 30 require law enforcement to intervene upon and either or both investigate and prosecute reported criminal activity of military, federal government, and defense contractor staff all acting within their official capacity. 5. Did petitioner, as the plaintiff in the District Court, plead factual matter that, if taken as true, sufficiently alleges in support of federal causes of action or other remedies within the jurisdiction of federal courts? iii PARTIES TO THE PETITION Petitioner in this Court, plaintiff-appellant William Henry Starrett, Jr., was Plaintiff in the district court and an appellant before the Fifth Circuit. Below, he may also be referred to as ; “STARRETT” or “Plaintiff.” Respondent, defendant-appellee, having : appearance made in the district court and Fifth Circuit proceedings is the City of Richardson, Texas. : Recorded in behalf of Respondent in the district court and Fifth Circuit proceedings as having interest in the outcome of this case was the City of Richardson, Texas’s counsel for this case, Mr. Stephen Robert Marsh, and insurer, Travelers Indemnity Company. . iv