Whether the Constitution confers a private right of action against an individual State when that State violates the explicit prohibitions against slavery and involuntary servitude of Section 1 of U.S. Const. amend. XIII

QUESTION PRESENTED Borrowing the form of Justice Alito’s framing of the question presented in Dobbs v. Jackson Women’s Health Organization, No. 19-1392 (June 24, 2022), in this case “[t]he critical question is whether the Constitution, properly understood, confers a [private right of action against an individual State when that State itself violates the explicit prohibitions against slavery and _ involuntary servitude of Section 1 of U.S. Const. amend. XIII]” by and through a State-employed probation and parole officer who makes personal sex slaves of female probationers and parolees while they are in the State’s care and custody. “In Jones[v. Alfred H. Mayer Co., 392 U.S. 409, 439 (1968)], the Court left open the question whether § 1 of the [13th] Amendment by its own terms did anything more than abolish slavery. It is also appropriate today to leave that question open.” Memphis v. Greene, 451 U.S. 100, 126 (1981). See also. General Building Contractors Ass'n v. Pennsylvania, 458 U.S. 375, 390 n.17 (1982) (‘We need not decide whether the Thirteenth Amendment anything more than _ the abolition of slavery.”). Today is the day for the Supreme Court of the United States to answer the question finally and formally. Stephanie Logsdon Smith, Bridgett Dennis Parson and Cammie Musinski (collectively the “Petitioners”) are each someone’s mother, sister, daughter, wife and citizens of the United States of ii America with all rights appurtenant thereto. After mild brushes with the law, each was on probation or parole in the care and custody of the Commonwealth of Kentucky Department of Corrections under the supervision of Ronald Tyler—hired, trained, supervised, and employed by the Commonwealth of Kentucky. Tyler repeatedly threatened to taint and falsify Petitioners’ court mandated drug test urine specimens, revoke their probation or parole and send them back to hell if they did not comply with his sexual demands. Scared and powerless to resist Tyler’s state authority, the women were raped and sexually assaulted by Tyler at will multiple times— his personal sex slaves. Sometimes he did not even bother to remove his state-issued badge and gun before sex. Tyler and the head of the Department of Corrections were fired by their employer, the Commonwealth of Kentucky. Tyler was indicted and prosecuted by his former employer, the Commonwealth of Kentucky, on multiple counts of rape and sodomy of multiple female probationers and parolees he supervised in addition to the Petitioners. Yet, after the filing of this lawsuit, Tyler was inexplicably permitted by the Commonwealth of Kentucky to plead guilty on November 16, 2021, in Bullitt County, Kentucky, state court to a single count of official misconduct with no input from the victims. The Federal Bureau of Investigation and the Department of Justice investigated. Tyler was indicted by a federal grand jury on July 19, 2022, and arrested by the FBI on July 22, 2022. He is charged with four counts of violation of 18 U.S.C. § 242 (with iii aggravated sexual abuse) and one count of violation of 18 U.S.C. § 1512.