Does a state supreme court violate the Equal Protection Clause by reading state statutes to preclude its largest city from protecting Black citizens from institutionalized, racially-disparate police conduct specifically found unconstitutional by the Department of Justice?

Questions Presented 1. Does a state supreme court violate the Equal Protection Clause by reading state statutes to preclude its largest city from protecting Black citizens from institutionalized, racially-disparate police conduct specifically found unconstitutional by the Department of Justice? 2. Does a state supreme court violate the Necessary and Proper Clause by interpreting state statutes to preclude municipal police review boards from holding subpoena power or accessing certain internal affairs records, when the existing process has been found unconstitutional by the Department of Justice? 3. Does a state supreme court violate the Constitutional Separation of Powers doctrine by holding that the state executive’s police oversight regulations preempt the state legislature’s delegation of police oversight authority to municipalities? ii II. Related Cases Statement The City of Newark, by and through counsel Pashman Stein Walder Hayden PC, respectfully petitions this Court for a writ of certiorari to review the August 19, 2020 Opinion and Order of the New Jersey Supreme Court. The directly related matters comprise the underlying United States Department of Justice civil rights litigation, and the proceedings below: 1. New Jersey Supreme Court: Fraternal Order of Police Newark Lodge No. 12 v. City of Newark, Docket No. A-15-19. Resolved by published Opinion dated August 19, 2020. 2. New Jersey Superior Court, Appellate Division: Fraternal Order of Police Newark Lodge No. 12 v. City of Newark, Docket No. A-3298-17. Resolved by published Opinion dated June 18, 2019. 3. New Jersey Superior Court, Chancery Division: Fraternal Order of Police Newark Lodge No. 12 v. City of Newark, Docket No. C-177-16. Resolved by oral ruling dated March 14, 2018. 4. United States District Court for the District of New Jersey: United States v. City of Newark, Docket No. 2:16-cv-1731. Resolved by five-year Consent Decree entered May 5, 2016. ili Ill. Tables of Contents and Authorities