Should the Supreme Court adopt Chapman v. Pier 1 Imports as a national standard to balance the need to deter abusive serial ADA filings with the need to afford relief to legitimate ADA claimants?

QUESTIONS PRESENTED FOR REVIEW Definition: “ADA” refers to the Americans with Disabilities Act of 1990, 42 U.S.C. § 12101 et seq. 1. Should the Supreme Court adopt, as a national standard, Chapman v. Pier 1 Imports (U.S.) Inc., 631 F.3d 939, 944 (9th Cir. 2011), to balance the need to deter abusive serial ADA filings with the need to afford relief to legitimate ADA claimants, by requiring the ADA plaintiff to plead and prove standing for each ADA non-compliance item alleged, as a condition for recovery of attorney's fees and costs? 2. Does a ADA defendant’s stipulation to fix certain ADA non-compliance items preclude it from seeking Rule 11 sanctions against a serial ADA plaintiff for false assertions pleaded on her complaint? 3. Does the Court of Appeals lose jurisdiction to entertain a post-mandate motion for attorney’s fees brought under Ninth Circuit Court of Appeals, Circuit Rule 39-1.6? 4. Is Ninth Circuit Court of Appeals, Circuit Rule 39-1.6, unconstitutional because it authorizes the Court of Appeals to decide post-appeal fee motions, thereby depriving parties of their right to appellate review?