Are employer statements on religious discrimination binding judicial admissions in a Title VII de novo review?

QUESTIONS PRESENTED 1. Are employer statements on religious discrimination that are included in the complaint and admitted in the answer binding judicial admissions in the de novo review of a federal employee’s Title VII religious discrimination claim? 2. Is a Final Agency Decision that was not vacated competent evidence in the de novo review of a federal employee’s Title VII religious work environment claim? 3. As “[t]he loss of First Amendment freedoms, for even minimal periods of time, unquestionably constitutes irreparable injury” and as “[Title VII] gives [religious practices] favored treatment”, can discrimination or harassment of a federal employee based on religion be considered “the ordinary tribulations of the workplace”? 4. Was the law prohibiting religious discrimination in the workplace clearly established in 2013 to preclude qualified immunity as a defense to a claim for damages under the Religious Freedom Restoration Act? 5. Is qualified immunity a defense to a claim for equitable relief under Title VII or under the Religious Freedom Restoration Act? 6. Is a sanction that abridges substantive rights for a non-willful violation of a local rule proper under Federal Rule of Civil Procedure 83(a)(2). ii LIST OF PROCEEDINGS Casey Campbell v. William P. Barr, Attorney General of the United States; United States Department of Justice; Federal Bureau of Prisons; and William Onuh, Civil Action: 3:19-cv-01887-L in the U.S. District Court for the Northern District of Texas, Dallas Division, Transfer Order July 21, 2021. Casey Campbell v. William P. Barr, Attorney General of the United States; and William Onuh, Civil Action: 3:20-cv-01605-G in the U.S. District Court for the Northern District of Texas, Dallas Division, Transfer Order June 19, 2020. Casey Campbell v. William P. Barr, Attorney General of the United States; and William Onuh, Civil Action: 4:20-cv-00638-P in the U.S. District Court for the Northern District of Texas, Fort Worth Division, Final Judgment June 19, 2020. Casey Campbell v. Robert M. Wilkinson, Acting U.S. Attorney General; and William Onuh, Appeal 20-11002, in the U.S. Court of Appeals for the Fifth Circuit, Judgment February 19, 2021 988 F.3d 798 (5th Cir. 2021). In re Casey Campbell, Civil Action: 4:21-cv-00881-P in the U.S. District Court for the Northern District of Texas, Fort Worth Division, Final Judgment September 16, 2022. Casey Campbell v. Merrick B. Garland, Attorney General of the United States; and William Onuh, in his official capacity and in his personal capacity, Appeal 21-10133, in the U.S. Court of Appeals for the Fifth Circuit, Judgment November 2, 2023.