Arthur J. Clemens, Jr. v. Local One Service Employees International Union, et al.
JusticiabilityDoctri
Should 29 USC 481(c) be declared Unconstitutional
QUESTIONS PRESENTED 1. Should 29 USC 481(c) be declared Unconstitutional by the Supreme Court and the case remanded to the Eighth Circuit or the Trial Court with instructions to take steps to transform Local One, SEIU from being an authoritarian dictatorship with sham elections into a democratic institution with fair elections? 2. Did the Court of Appeals err by failing to appoint a Class Counsel to represent the financial interests of the rank and file members of Defendant Local One, SEIU, pursuant to 29 USC 501 and argue on behalf of insuring the 1* Amendment Freedom of Assembly Rights of the 50,000 rank and file members of Defendant Local One, SEIU, and 15 million members of Unions nationwide, and the 14" Amendment Equal Protection rights of candidates for Union office, including the Petitioner, in keeping with Rule 23, FRCivP and in the spirit of Gideon v. . . Wainwright, 372 U.S. 335? 3. Is the Eighth Circuit Court of Appeals responsible for enforcing the ethical standards required of the Eighth Circuit by the Supreme Court in the case of In Re Snyder, 472 U.S. 634 in this case? 4, Has the Eighth Circuit failed to require the Trial Court to meet the standards set by the Supreme Court in the cases of Celotex Corp. v. Catrett, 477 U.S. 317 and United States v. El Paso Natural Gas Co., 376 U.S. 651 when granting Summary i Judgment to the Respondents in the First and 11'" Causes of Action of the . Petitioner’s Amended Complaint? 5. Has the Eighth Circuit allowed the “exhaustion of remedies” defense to be used — to justify acts that are a violation of Federal and Missouri State criminal statutes, and/or otherwise expanded the “exhaustion of remedies” defense beyond reasonable limits? ii