Whether a state-created statutory right to file discrimination charges constitutes a property interest under the Fourteenth Amendment that protects against intentional interference by federal and state officials that deprive claimants of access to local adjudication and judicial review

1 I. Cause of Action as Property Right Under the Fourteenth Amendment Whether a state-created statutory right to file discrimination charges and receive notice of their disposition, which constitutes a cause of action recognized as a property interest under the Fourteenth Amendment as discussed in Logan u. Zimmerman Brush Co., 455 U.S. 422, protect against intentional interference by federal and state officials —such as overriding EEOC regulations, misfiling charges, or withholding required notices —that deprive claimants of access to local adjudication and judicial review, thereby violating procedural due process and the protections of 42 U.S.C. §§ 1983 and 1985, especially when such actions result in the exclusion of similarly situated individuals from statutory grievance processes and undermine the constitutional requirement that all such individuals be treated equally II. Color of Law and Federal-State Collusion Whether, consistent with the pleading standards articulated in Gomez v. Toledo, 446 U.S. 635, and Adickes v. S. H. Kress & Co., 398 U.S. 144, and the federal-state actor analysis set forth in Cabrera v. Martin, 973 F.2d 735, 742 —43, a plaintiff states a claim under 42 U.S.C. §§ 1983 and 1985 —and establishes the necessary “symbiotic relationship ” for federal officials to be considered state actors —by alleging that federal and state officials conspired to intentionally 1 To prevent a later improvidently granted dismissal, I have listed these numerous questions to secure my right to jury trial. See Stanley v. City of Sanford, Fla., 145 S. Ct. 2058 (2025) 2 obstruct access to state statutory remedies for employment discrimination, including the misfiling of charges, denial of statutory grievance procedures, withholding of mandatory notice, and thereby depriving the plaintiff of protected property interests, equal protection, and due process under the Fourteenth Amendment —and whether such conduct may fairly be attributed to the state for purposes of constitutional review. III. Heighten the Pleading Standard and Violation of Rule 12(d): Failure to Convert to Summary Judgment Whether, in fight of the Supreme Court ’s decisions in Swierkiewicz v. Sorema N.A., Johnson v. City of Shelby, Erickson v. Pardus, federal courts may dismiss employment discrimination claims at the pleading stage by requiring factual allegations that exceed the notice standard of Federal Rule of Civil Procedure 8(a)(2), effectively mandating plaintiffs to plead a prima facie case under the McDonnell Douglas framework and applying heightened plausibility standards, notwithstanding the Court ’s explicit rejection of heightened pleading standards and in potential violation of the Seventh Amendment ’s guarantee of trial by jury, thereby deepening a circuit split, disproportionately burdening pro se litigants, and undermining access to judicial review. IV. Individual Immunity Under § 1981 Whether management-level human resources personnel (or any employee) and their subordinates, may be held individually liable under 42 U.S.C. § 1981 for purposeful, intentional discrimination, and, if so, whether a plaintiff must plead detailed evidence of discriminatory intent or whether allegations of personal 3 involvement and animus suffice under Federal Rule of Civil Procedure 8 and Swierkiewicz; and whether inconsistent pleading standards and the absence of controlling appellate precedent in the Eighth Circuit warrant review to resolve the deepening circuit split and to ensure equal access to judicial remedies pursuant to the Fourteenth Amendment. V. Threshold question regarding pleading requirement to establish specific personal jurisdiction in an out-of-state employment case Whether out-of-state corporate officials who repeatedly enter a forum state to conduct mandatory training and enforce disciplinary policy against a forum-based employee have sufficient minimum contacts to support personal jurisdiction under the Due Process Clause and Minnesota ’s long-a