Kenneth Howard Kerr, III v. Bobby Lumpkin, Director, Texas Department of Criminal Justice, Correctional Institutions Division
DueProcess
Did the Petitioner state enough facts (included in his attachments as well as the text) to present a valid claim?
QUESTIONS PRESENTED i Did the Petitioner state enough facts (included in his attachments as well as the text) to present a valid claim? In Did the Petitioner state enough facts (included in th his» attachments as well as the text) to present a claim of due process violations? SIL Did the Petitioner show “injury in fact"? : tv. Did the Petitioner state enough facts (included in his attachments as well as the text) to present a claim of equal ~ protection violations? uw Is TDCJ-RPD limmiting the Petitioner's lst Ammendment Right to Freedom of Speach by preventing him the equal opportunity to reform by denying him the knowledge needed to re-entergrate upon his release? VL Is the fact that the Petitioner is being denied the right to be treated the same as other similarly situated prisoners (S3-G2 Class) denying him the equal opportunity at re-entergration into ; society upon his release going to cause harm that reaches beyond the scope of his period of incarceration to be considered a fact ii why Me aL in violation of Packingham_vNorth Carolina, 137 S.ct 1730 (2017)? VIL By denying sex offenders the opportunity to learn how to use ‘ the computer to learn skills such as Computer Aided Drafting and Office Applications in order to obtain jobs as Administrative Assistants, is not TDCJ-RPD as well as TDCJ-ID in general, z attempting to prevent sex offenders from having the same chance at survival as other similarly situated offenders and an equal opportunity at re-entegrating into society? IIT Has the petitioner herein shown "injury in fact" because he is being denied the equal opportunity to survive in society upon his release?