Whether the Feres Doctrine invalidates Title VI remedies for workplace discrimination experienced by a dual-status technician while performing civilian duties

QUESTIONS PRESENTED 1. Contrary to Congress’ clear intent, does the Feres Doctrine invalidate all remedies under Title VI for workplace discrimination experienced by a dual-status technician while performing her nonmilitary duties as a civilian Aircraft Mechanic? Further, are some of the Circuits below, e.g., the Fifth Circuit, determining a_ dual-status technicians’ (“DTS”) EEOC access per 32 U.S.C. § 709 properly under the incident to service or irreducibly military in nature test which serves as acomplete bar to civilian DTS discriminated in the civilian military workforce. Or are other Circuits correct in preventing EEO access to DTS where the cause of action is only integrally related to military function which does not serve as a complete bar to the EEO. 2. Faced with repeated refusals to comply by federal and state agencies, can the Equal Employment Opportunity Commission (“EEOC”) shirk its duty to enforce its own decision that a federal employee experienced workplace discrimination? 3. Can multiple federal and state agencies be represented by the same counsel when clear conflicts of interest exist between these agencies?