Whether individuals challenging government travel restrictions have Article III standing to pursue claims under the DHS Traveler Redress Inquiry Program when denied substantive agency responses

No question identified. : 1 To the Honorable John G. Roberts, Jr., Chief Justice of the Supreme Court of the United States and Circuit Justice for the D.C. Circuit: _ Petitioners Mohammed Jibril, Aida Shahin, individually and on behalf of their minor children Y.J. and O.J., and Ala’a Jibril, Khalid Jibril, and Hamza Jibril pray for a forty -five day extension to file their petition for writ of certiorari in this Court, up to and including September 25, 2024. The United States Court of Appeals for the D.C. Circuit issued its Opinion on May 14, 2024, affirming the decision of the District Court for the District of Columbia to dismiss Petitioner’s claims. Jibril v. Mayorkas , 101 F.4th 857 (D.C. Cir. 2024); No. 23-5074, United States Court of Appeals for the D.C. Circuit (Judgment entered May 14, 2024; Mandate issued July 9, 2024) . Petitioners ’ deadline to file a petition for a writ of certiorari is Monday, August 12 , 202 4. While this Motion is not within the full ten days p ursuant to Rule 13.5, Petitioner s file this application as soon as the need became apparent and within seven (7) days of the due date of the petition . Petitioner s also attach a copy of the opinions below, pursuant to Rule 13.5. This Court has jurisdiction under 28 U.S.C. § 1254. Petitioner s file this application as to themselves , via their counsel, and not on behalf of any other parties. The D.C. Circuit’s Opinion in this matter presents several significant issues that are ripe for review by this Court. Petitioner s raise questions concerning standing of individuals who file complaints under the Department of Homeland Security’s 2 Traveler Redress Inquiry Program (“DHS TRIP”) in light of the reasoning expressed by this Court in its recent holding in FBI v. Fikre , 601 U.S. 234 (2024) and other relevant opinions, including the degree of appropriate agency deference afforded in light of Loper Bright Enters. v. Raimondo , 144 S. Ct. 2244 (2024) . Specifically, the lower courts held that Petitioners lack standing to challenge their treatment while traveling because of their potential (and unconfirmed to them or their counsel ) interim removal from the Terrorist Screening Dataset, despite the government’s repeated refusal to provide confirmation at any stage of the proceed ings to Petitioners or their counsel of this status. Litigation began in this matter in 2019 after the Jibril family members received no substantive responses to their DHS TRIP complaints. Nonetheless, the lower courts dismissed the case based on lack of standing due to purely in camera submissions and hypotheticals provided in the district court opinion. The undersigned counsel, Christina A. Jump, serves as the Civil Litigation Department Head for the Constitutional Law Center for Muslims in America (“CLCMA”). Currently, she appears as lead counsel on fourteen (14) active federal court civil litigation ca ses, in addition to a docket of numerous administrative -level matters and her management responsibilities inherent in supervising a department. CLCMA is a small nonprofit law center with a nationwide federal practice, and lean staffing. Ms. Jump therefore has limited ability to delegate to many other attorneys. Multiple problems unexpectedly arose in the past two weeks, causing Ms. Jump and the rest of her department great difficulty in proceeding with drafting the 3 petition in this matter. These include the departure of one attorney, and illnesses affecting Ms. Jump and the only other two attorneys assigned to this matter. In addition, Ms. Jump is lead counsel of record in the fourteen (14) pending federal court litigation matters referenced above as well as one state proceeding, and multiple active civil rights complaints on behalf of dozens of students and faculty at higher education institutions across the country. These include, among others, complaints filed o n behalf of students at Harvard University and Brown University. The same two other attorneys who have also been ill