Whether fraudulent misrepresentation and conspiracy-to-defraud are preempted

QUESTION PRESENTED NUMBER 1 Congress enacted The Individuals with Disabilities Education Act (IDEA) “(1)(A) to ensure that all children with disabilities have available to them a free appropriate public education that emphasizes special education. . .”“(B) to ensure that the rights of children with disabilities and parents of such children are protected”. 20 U.S.C. §1400(d)(1). Congress went further : to require the Education Department to develop and publish model IEP, IFSP, Procedural Safeguard Notice, and Prior Written Notice forms. 20 U.S.C. §1417(e). These model forms are required to be used by school districts to meet the requirements of IDEA in order to assess children in all areas of suspected disabilities and further provide an individualized education pro; . gram (IEP). QUESTION PRESENTED: Whether fraudulent misrepresentation and ; conspiracy to defraud are preempted, when the Educational federal statutes touch a field in which the federal interest is so dominant, that the federal system must be assumed to preclude enforcement of state laws and the District Court should have granted the peti; tion and pleading pursuant to 28 U.S. Code §1367 Supplemental jurisdiction under Article III of the United States Constitution for claims and evidences that are inextricably related. | ii : QUESTIONS PRESENTED—Continued QUESTION PRESENTED NUMBER 2 In light of this Court’s recognition in Ex Parte Young, 209 U.S. 123 (1908) that “While this court will not take jurisdiction if it should not, it must take jurisdiction if it should. It cannot, as the legislature may, avoid meeting a measure because it desires so to do.” : QUESTION PRESENTED: ; Whether the District Court was biased to dismiss the case pertinent to claim on prior rul: ing that the court remanded the case because the court had not ruled on State Criminal removal in 15 years, and violated the Equal Pro. tection Clause, by failure to grant Equitable . relief and restore substantial loss and impairment of freedoms of expression and speech, : rights under the Fourth, Fifth, Sixth, Eighth and Fourteenth Amendments and due process ; clause to the Constitution of the United States of America. iii ;