Whether the retaliation protection provision of Title VI of the Civil Rights Act of 1964 should continue to require non-disabled plaintiffs to prove the heightened 'but for' standard or be changed to only require proof of mixed motives

No question identified. : af ‘ ‘ ‘ ' ' cog th a ; i a ' RELIEF REQUESTED ~ : Having previously submitted this pleading as a Rule 22 Application , which the Clerk rejected , Petitioner re-submits. Former schoolteacher Petitioner requests extraordinary relief from the Ninth Circuit Court of Appeals’ infection by Democratic political bias, as this infection constitutes absence of a rational basis and improper personal motives and thus violates ; the Constitution’s equal protection clause when : 7 compared to other Cireuits, He requests extraordinary : order for investigation as described herein and that ; ue ; his case be reheard in a ‘different circuit, and that the — Ninth Circuit reasonably pay the bill for re-location of , discovery and trial. Applicant additionally requests . a consideration of the following: , . . 1. Whether the retaliation protection provision of . ; Title VI of the Civil Rights Act of 1964, in regard to it’s current application to §504 protected complaints lodged by non-disabled individuals but on behalf of disabled individuals, should continue to require those noin-disabled Plaintiffs to prove the heightened LC A . g a f . i standard that their employers would not have taken any adverse action against them “but for’ the existence of an improper retaliatory motive, (the “Nassar test”); or should the Court reconsider University of Texas Southwestern Medical Center v. Nassar, 570 U.S. 338 (2013) , and the requirement ; be changed to only require proof that the employer had mixed motives for taking adverse action. 2. Whether the past ten years show that the Court’s prohibition on claims for equal protection under the 14th amendment by “class of one” public employees, established by the holding in Engquist v. Oregon Dep't of Agric., 553 U.S. 591 (2008), falls in line with the Constitution. EXCEPTIONAL CIRCUMSTANCES WARRANT EXERCISE OF THE COURT’S DISCRETIONARY POWERS, AND ADEQUATE RELIEF CANNOT BE OBTAINED IN ANY OTHER FORM OR FROM : ANY OTHER COURT In this case, an innocent public employee high school Art teacher, (Petitioner), despite six years of , struggle as a Pro Se in the Ninth Circuit, has had his i whole career and personal reputation viciously permanently destroyed by California state officials aided by Ninth Circuit Federal jurists, and his | professional license revoked, without rational basis : and because of improper personal motives. The improper motive was to protect figurehead Democrat politician and now presidential candidate Sen. Kamala Harris from exposure for aiding and abetting corrupt plain alteration of a date in, and plain suppression of witness statements from, LAPD detectives report No. 12-09-11015 at Petitioner’s high school, (the “detective’s report”.) This occurred during Harris’ final days as California’s Attny. General, (see Petitioner’s uncontroverted affidavit re. Harris’ acts related to the detective’s report in this case as Exhibit to his initial brief in the Ninth Cir. Appeal No. 1656484, Dkt. Entry 9, pg. 47 of 63, and also attached to this petition as app’x 2). When Petitioner went to the Hill Street USDC Courthouse manual filing window in Los Angeles to attempt to manually file a proposed \ es iv redlined amended complaint in the instant case, adding Kamala Harris as a defendant, an unusual clerk came out from a back office, or was summoned from a back office, a middle aged African American woman who appeared to be a supervisor. She told Petitioner that she would “give all of this” to Judge Dolly M. Gee, the district judge in this case. (Petitioner inadvertently did not have a face page of the required redlined version to stamp). Judge Dolly M. Gee thereafter entered untruthful statement in the docket that Petitioner never filed the red lined version, as her justification for rejecting amendment and thus rejecting Harris as a defendant. » ? . « v