In Re Billy Marvin Witt, III, et ux.
1. Whether the warrantless arrest and 24-hour detention of Petitioner Billy Marvin Witt III on April 3, 2024, violated his constitutional rights under the Fourth, Fifth, and Fourteenth Amendments.
2. Whether the warrantless arrest and subsequent strip search of Co-Petitioner Jeanie Rochelle Witt on April 3, 2024, violated her constitutional rights under the Fourth, Fifth, Eighth, and Fourteenth Amendments, especially considering her disability and lack of probable cause.
3. Whether the ongoing pattern of harassment and retaliation by Clay County law enforcement —including a militarized four-hour standoff at Petitioners ' home on July 2, 2024, repeated predatory traffic stops by multiple officers, and the stacking of new felony charges arising from the April 3rd incident —justifies this Court 's extraordinary intervention.
4. Whether the practice of judicial overreach, including entering pleas for defendants against their will, coercing pleas under duress, and denying defendants the opportunity to present medical hardship evidence, violates constitutional due process guarantees.
5. Whether the use of a 25-year-old Oklahoma conviction-without establishing its validity, finality, or eligibility for use as a sentencing enhancement under Texas law-to increase the severity of current criminal charges violates Petitioner Billy Witt 's rights to due process and fundamental fairness.
6. Whether the June 18, 2025 arrest of Petitioner Billy Marvin Witt III, and his continued detention under unsigned or invalid warrants, violated his constitutional rights when no judicial officer with lawful authority ever issued or executed the warrants.
7. Whether the search justification report used to defend the April 3, 2024 strip search of Co-Petitioner Jeanie Rochelle Witt—claiming discovery of narcotics that were never found —constitutes the falsification of an official record in violation of the Fourteenth Amendment 's guarantee of due process.
8. Whether the absence of any transportation logs documenting Co-Petitioner Jeanie Rochelle Witt 's custody and transfer following her April 3, 2024 arrest violates the constitutional requirements for procedural due process and accountability in detention.
9. Whether the participation of Constable Ferguson (Badge #1500) and Constable 's Deputy Lowry (Badge #1501) in the June 18, 2025 raid—while acting as an "assisting agency " without body cameras, official reports, or judicial authorization —constitutes a violation of Petitioners ' rights under the Fourth and Fourteenth Amendments and underscores a broader failure of inter-agency oversight in Clay County law enforcement.
10. Whether repeated interference by Clay County officials with Petitioners ' legal mail, electronic communications, and ability to participate in state proceedings-including delays preventing time-sensitive filings, obstruction of attorney correspondence, and intimidation preventing Co-Petitioner Jeanie Witt from safely entering the jail or courthouse-renders ordinary state remedies unavailable or ineffective within the meaning of Supreme Court Rule 20 and violates Petitioners ' rights under the First and Fourteenth Amendments.
11. Whether the complete breakdown of Clay County's administrative grievance system —demonstrated by Petitioner Witt's grievance to the Jail Administrator being returned "VACANT " while the Sheriffs Office simultaneously identified Captain Johnston, the same officer who conducted the unlawful April 3rd, 2024 strip search and falsely reported narcotics in Petitioner's vehicle, as the
Whether warrantless arrests, strip searches, pattern harassment, judicial overreach, invalid sentencing enhancements, unlawful detention, falsified records, and interference with legal remedies by Clay County law enforcement and judicial officers violated Petitioners' constitutional rights under the Fourth, Fifth, Eighth, and Fourteenth Amendments, warranting this Court's extraordinary intervention under Supreme Court Rule 20