Do the United States Court of Appeals have obligations to enforce FRCP 56 and the Supreme Court's precedents when Statement of Material Facts and supporting records filed by movants, pursuant to Local Rules, contradicted other records filed pursuant to FRCP 56?

QUESTIONS PRESENTED Supreme Court precedents require, “The evidence of the nonmovant is to be believed, and all justifiable inferences are to be drawn in his favor.” Anderson. v. Liberty Lobby, Inc., 477 U.S. 242, 255, 106 S.Ct. 2505 (1986); Tolan v. Cotton, 572 U.S. 650, 659, 134 S.Ct. 1861, 1868 (2014). Further, Supreme Court precedents require that credibility determinations be left for the jury, and have held that the jury’s disbelief of the employer is a “form of circumstantial evidence that is probative of intentional discrimination.” Reeves v. Sanderson Plumbing Prod., Inc., 5380 U.S. 1338 (2000). Further, in First Amendment retaliation injury contexts, the Supreme Court precedent warrants an “independent” review to apply facts to specified constitutional standards. E.g. Bose Corp. v. Consumers Union of U.S., Inc., 466 U.S. 485, 499 (1984). There are some inter-circuit and intra-circuit disputes about whether Plaintiffs must be “chilled” and cease exercising their First-Amendment rights altogether to demonstrate an injury. Also, the objective criteria on how to examine and decide “blasphemous insults” as “pervasive” or “severe” are lacking because, individual perceptions and opinions differ, and one often cannot fathom the trauma of religious insults to a person from another religion. Thus, the QUESTIONS PRESENTED are as follows: 1. Do the United States Court of Appeals have obligations to enforce FRCP 56 and the Supreme Court’s precedents when Statement of Material Facts and supporting records filed by movants, pursuant to Local Rules, contradicted other records filed pursuant to FRCP 56? Specifically, should Courts admit movants’ Siatement of Material Facts and assertions, pursuant to Local Rules, even when contradicted by records filed pursuant to FRCP 56 by movants and/or ii nonmovants? Further, should Courts grant summary judgment for movants based on movants’ Statement of Material Facts and assertions, even when the full record, filed pursuant to FRCP 56 by nonmovants and/or movants show there are “genuine” disputes to material facts? 2. In the context of First Amendment claims, do the United States Court of Appeals have obligations to independently review the entire record, and not simply accept the lower Courts’ erroneous factual findings, based on Courts’ strict interpretation of Local Rules, even when nonmovants’ evidence, filed pursuant to FRCP 56, contradicts movants’ Statement of Material Facts, evidence, or assertions? 3. What is the appropriate standard for “chilling” to sustain a First Amendment injury claim? Specifically, in order to sustain an injury claim under First Amendment rights, are public or government employees always required to show that they ceased speaking altogether on matters of public concern? 4. What is the objective standard for determining whether blasphemous insults to employees at the workplace by supervisors against employees’ religion are “severe” or “pervasive” in the context of workplace harassment to sustain discrimination and/or “hostile work environment” claims? How should Courts examine the effects of religious insults on employees, since religious beliefs are personal and vary widely among societies and religious backgrounds? Further, should the United States Court of Appeals not accept employees’ testimonies and email records as credible and require further corroborating evidence, despite movants’ lack of contrary evidence; and if so, what quality or quantity or type of corroborating evidence should the United States Court of Appeals demand to prevail at the summary judgment stage?