Whether a lower court's unexplained and unjustified delay in docketing a pro se litigant's motion violates the Fifth Amendment's Due Process Clause and constitutes an unconstitutional deprivation of access to the courts

1. Whether a lower court ’s unexplained and unjustified delay in docketing a pro se litigant ’s motion —thereby prejudicing the petitioner ’s substantive rights —violates the Fifth Amendment ’s Due Process Clause and constitutes an unconstitutional deprivation of access to the courts. 2. Whether a court ’s invocation of the mootness doctrine to dismiss a mandamus petition — where the underlying delay was caused by judicial inaction —contravenes fundamental principles of due process and this Court ’s jurisprudence, including Mathews v. Eldridge, 424 U.S. 319 (1976). 3. Whether the D.C. Circuit ’s misapplication of the “egregious delay ” standard from Telecommunications Research & Action Center v. FCC, 750 F.2d 70 (D.C. Cir. 1984), and its failure to conduct a fact-specific inquiry into the prejudicial impact of procedural delays on pro se litigants warrant this Court ’s review to establish a uniform national standard for adjudicating judicial inaction in indigent cases. 4. Whether systemic judicial delays that disproportionately impact indigent and pro se litigants require heightened procedural safeguards to ensure compliance with 28 U.S.C. § 1915 and the fundamental right to access the courts. 5. Whether the Supreme Court should intervene to clarify that the right to meaningful access to the courts, as recognized in Boddie v. Connecticut, 401 U.S. 371 (1971), includes protection against strategic procedural nullification, where judicial delays functionally deprive litigants of their constitutional claims. Core Precedents Supporting Petitioner ’s Constitutional Claims ♦ Due Process & Access to Courts 1. Mathews v. Eldridge, 424 U.S. 319 (1976) • Holding: Due process requires a fact-specific inquiry into procedural fairness before depriving a party of legal rights. • Relevance: The D.C. Circuit ’s failure to assess the harm caused by the 46-day delay contradicts this requirement, necessitating SCOTUS intervention. 2. Boddie v. Connecticut, 401 U.S. 371 (1971) V, V Page 3 of 34 • Holding: Access to the courts is a fundamental right under the Due Process Clause, particularly for indigent litigants. • Relevance: The judiciary ’s procedural bottleneck deprived Petitioner of meaningful access to judicial relief, violating this principle. 3. Turner v. Rogers, 564 U.S. 431 (2011) • Holding: Courts must implement procedural safeguards to ensure fair treatment of indigent litigants, even in civil proceedings. • Relevance: The lower courts ’ failure to apply heightened protections for a pro se indigent litigant is inconsistent with Turner ’s due process mandate. 4. Ex parte Hull, 312 U.S. 546 (1941) • Holding: The judiciary cannot create procedural barriers that prevent litigants from accessing the courts. • Relevance: The 46-day delay in docketing Petitioner ’s IFP motion constitutes an unconstitutional procedural obstruction in violation of Hull. ♦ Mootness Doctrine & Judicial Accountability 5. Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., Inc., 528 U.S. 167 (2000) • Holding: The mootness doctrine cannot be manipulated to evade judicial review where the harm remains unresolved. • Relevance: The D.C. Circuit ’s dismissal as “moot” allowed the judiciary to shield its own procedural failure from appellate review, contradicting Laidlaw ’s principles. 6. United States v. W.T. Grant Co., 345 U.S. 629 (1953) • Holding: Voluntary cessation of unconstitutional conduct does not moot a case unless there is no reasonable expectation of recurrence. • Relevance: The D.C. Circuit ’s ruling ignores the ongoing harm caused by strategic judicial delays, improperly applying the mootness doctrine. 7. Church of Scientology v. United States, 506 U.S. 9 (1992) • Holding: A case is not moot simply because the procedural posture has changed if the original injury remains. Page 4 of 34 • Relevance: The D.C. Circuit erred by failing to address the systemic harm of procedural nullification, contrary to this precedent. ♦ TRAC Standard & Egregious Delay 8.