Emem Ufot Udoh v. Minnesota Department of Human Services, et al.
SocialSecurity DueProcess HabeasCorpus CriminalProcedure Privacy
Whether pro-se-litigants are held to the same legal standards as counseled-litigants
QUESTIONS PRESENTED FOR REVIEW Question One: In the (a) Denial of Plaintiffs Motions, Whether “Pro Se Litigants” are Held to the Same Legal Standards as “Counseled Litigants” in light of Haines v. Kerner, 404 U.S. 519 (1972); Davis v. Monroe County Bd, 526 U.S. 629 (1999); Erickson v. Pardus, 551 U.S. 89 (2007); Skinner v. Switzer, 562 US 521 (2011)? Question Two: Whether Parent(s) May Assert a Fourth Amendment Challenge Regarding a Search and Seizure of their Minor Children? Question Three: Whether Evidence of “Reasonable Suspicion of Child Abuse” Standard Does Not Apply To Plaintiffs §1983 (a) Fourth Amendment Warrantless Entry to Home to Conduct Search and Right to Privacy; (b) Fourteenth Amendment Stigma-Plus Preclusion to Seek Employment in their Chosen Profession and Procedural Due Process Claims; and (c) §1985 Conspiracy Claim for Qualified Immunity Purposes? Question Four: Whether Government Entities Such as City Of Plymouth, City Of Maple Grove, Hennepin County, CornerHouse and Minnesota Department of Human Services are Not Entitled to Judgment on Qualified Immunity Grounds for Municipal Liability in light of Monell v. Dep’t of Social Services, 436 U.S. 658 (1978); Pembaur v. Cincinnati, 475 US 469 (1986)? Question Five: Whether Defendants Violated Plaintiffs’ Clearly Established (a) Fourth Amendment and Minn. Const. Art. I, Sec. 10 Rights Against Unreasonable Search And Seizure, (b) Fifth Amendment Right to Miranda Warnings, and (C) Fourteenth Amendment Substantive And Procedural Due Process Rights and Art. I, Sec. 7 of Minn. Const. in light of Troxel v. Granville, 530 U.S. 57 (2000); Ferguson v. Charleston, 532 U.S. 67 (2001); Stanley v. Illinois, 405 U.S. 645 (1972); Stansbury v. California, 511 U.S. 318 (1994); Maine v. Thiboutot, 448 U.S. 1 (1980); Safford Unified Sch. Dist. v. Redding, 557 US 364 (2009)? Question Six: Whether Defendants Falsely Arrested and Imprisoned Plaintiffs and Caused Intentional Infliction Of Emotional Distress on All Plaintiffs? Question Seven: Whether Minn. Stats. §626.556 and §260.165 Now §260C.175 are Unconstitutional Facially and as Applied to Plaintiffs in light of Troxel v. Granville, 530 U.S. 57 (2000); Chicago v. Morales, 527 U.S. 41 (1999); Petition By Udoh — Page ii Ferguson v. Charleston, 532 U.S. 67 (2001); Stanley v. Illinois, 405 U.S. 645 (1972)? Question Eight: Whether Under the Circumstances of this Case, A Municipality Can Be Held Liable Under Monell For Arguing Enforcing or Adherence to State Laws MGDPA, Minn. Stats. §626.556 and §260C.175 in light of Monell v. Dep’t of Social Services, 436 U.S. 658 (1978)? Question Nine: Whether Competent Parent (Non-Attorney) May Proceed Pro Se on Behalf of their Minor Children to Challenge in a Federal Civil Court Violation of their Fourth and Fourteenth Amendments Constitutional Rights and State-Law Claims? Question Ten: Whether Individual Defendants are Not Entitled to Judgment on Qualified Immunity Grounds on All Plaintiffs §1983 and §1985 Claims? Petition By Udoh Page iii