I. First Amendment and Certificate of Appealability Standard
Whether this Court should grant certiorari —or exercise its supervisory authority —to directly
issue habeas relief where Petitioner was denied a Certificate of Appealability ("CO A") despite
being entitled to one as a matter of law, in a case where the record establishes that Petitioner
was knowingly prosecuted and imprisoned for protected, content-based speech, in direct
violation of controlling Firsf Amendment precedent (Stevens), and where such denial was
deliberately used to preserve false judicial findings that undermine both appellate jurisdiction
and the integrity of 28 U.S.C. § 2254 review.
II. Deliberate Judicial Inversion and Fraud on the Court
Whether this Court should exercise its inherent constitutional and supervisory authority to
remedy fraud on the court where state and federal judges —including the Maryland Appellate
Court in Schiff v. State, No. 725 (Md. Ct. Spec. App. 2022), and the District Court in Schiff v.
Maryland, No. TDC-22-3332 (D. Md.) —knowingly misapplied or fabricated First
Amendment doctrine by falsely labeling Petitioner 's speech "integral to criminal conduct, "
despite the absence of any criminal conduct, thereby transforming judicial proceedings into
instruments of censorship and retaliation, in violation of the First and Fifth Amendments and
Article III.
III. Alternative Grounds for Vacatur: Statutory Repeal and Jurisdictional
Collapse
Whether, independent of the First Amendment violations, Petitioner 's convictions must be
vacated as void ab initio because (a) Maryland 's stalking statute, Md. Code, Crim. Law § 3-802,
was repealed by 2024 Md. Laws Ch. 772 (effective Oct. 1, 2024) while Petitioner was still
serving probation; and (b) harassment jurisdiction under £ 3-803 —limited to offenses carrying a
90-day maximum penalty —resides exclusively in the Maryland District Court, rendering
Petitioner 's 2021 Circuit Court conviction void for lack of subject-matter jurisdiction because
it was only able to be prosecuted in that court due to attachment of now repealed 3-802.
IV. Supervisory and Systemic Relief to Restore Habeas and Appellate Integrity
Whether this Court should clarify that when lower courts intentionally deny relief to which a
habeas petitioner is entitled as a matter of law—particularly in cases involving protected speech
and judicial misconduct —the Supreme Court has both the supervisory and constitutional
authority to vacate the underlying judgments and restore jurisdiction, notwithstanding procedural
finality or COA denial, in order to prevent the perpetuation of void convictions and preserve the
supremacy of constitutional law over judicial or executive abuse.
Whether the Supreme Court should grant certiorari or exercise supervisory authority to address a First Amendment violation where a petitioner was denied a Certificate of Appealability despite being prosecuted for protected speech