Sohail N. Butt v. John Brigham Zimmerman, Individually and in His Official Capacity as Executive Director, Georgia Composite Board for Professional Counselors, Social Workers, and Marriage and Family Therapists, et al.
Petitioner Sohail N. Butt sought license to practice mental health counseling in the State of Georgia in 2014. Respondents at their board meeting evaluated, voted and unanimously agreed to grant Mr. Butt his license. The license never materialized.
Respondents violated Mr. Butt's constitutional right to equal protection before law and to due process of law with consequent denial of his constitutional right to pursue a calling of his choosing and the property right to earn a living contrary to U.S. Const., 14th Amend., Sec. 1. For almost nine years, Mr. Butt petitioned and appealed to every branch of state government seeking remedy. The State of Georgia has repeatedly "shut him down" and "tried to bury it". Now Respondents rely on Wilson v. Garcia, 471 U.S. 261 (1985) to claim the affirmative defense of statute of limitations to avoid liability under federal law.
Exceptional circumstances are presented to this Court. The Licensing Board did wrong but claimed sovereign immunity. Legal practitioners agreed, but in 2015 this Court stated otherwise. N.C. State Bd. of Dental Exam'rs v. FTC, 574 U.S. 494, 504 (2015). The Licensing Board did not enjoy sovereign immunity due to absence of supervision. In 2016 Georgia brought in law to comply with the ruling but offered no remedy and left a legal void.
The question presented is:
Petitioner is asking this court to waive the statute of limitations due to unique and exceptional circumstances. A just and equitable remedy is sought upholding the spirit and principles of laws.
Whether the petitioner's constitutional rights to equal protection and due process were violated by the respondents' denial of his license to practice mental health counseling, and whether the statute of limitations should be waived due to the exceptional circumstances presented