Whether federal bankruptcy law preempts state court possession orders that conflict with the automatic stay and federal courts' exclusive jurisdiction over bankruptcy estate property

No question identified. : INTRODUCTION Applicant respectfully seeks immediate relief under Rule 23 to preserve the status quo of federally protected property and pending federal proceedings. State-court possession and contempt orders were executed despite an automatic stay and the exclusive jurisdiction of the federal courts over estate property. Without temporary relief, the continuing enforcement risks mooting pending federal appeals and impairing this Court's jurisdiction. JURISDICTION AND PROCEDURAL POSTURE This Application is submitted to the Chief Justice, as Circuit Justice for the Fourth Circuit, under Rule 22 and Rule 23, in aid of this Court’s jurisdiction under 28 U.S.C. §§ 1651(a) and, where applicable, § 2101(f). Relief was first sought below: the U.S. District Court for the Eastern District of Virginia denied emergency relief on November 15, 2024, and the U.S. Court of Appeals for the Fourth Circuit denied a stay on May 14, 2025. Further relief is unavailable in the lower courts enforcement of state orders threatens to moot federal appeals and defeat this Court’s potential review. See Rule 23.3. STATEMENT OF FACTS 1. Applicant holds legal title to a VA-backed residence. 2. Bankruptcy was filed in 2024 in the Eastern District of Virginia and remains pending. 3. Despite 11 U.S.C. § 362 and the federal courts’ exclusive jurisdiction over estate property, state-court possession and contempt orders issued. 4. On April 10, 2025, the Sheriff executed removal; no foreclosure occurred and title was not adjudicated. The deed remains in Applicant’s name. 5. Appeals in the Fourth Circuit (Nos. 24-2160 and 25-1229) remain pending; continuing enforcement risks mooting those proceedings. ARGUMENT Emergency relief is warranted under the established stay factors. I. LIKELIHOOD OF SUCCESS ON THE MERITS Once bankruptcy commenced, federal courts exercised exclusive jurisdiction over the property; state proceedings in conflict are void. Removal of a deed holder without adjudication of title also triggers per se physical-occupation concerns. IT. IRREPARABLE HARM Loss of possession of a home and the risk of continued alteration or disposal are immediate and not compensable by later damages. Each day of dispossession deepens the injury. III. BALANCE OF EQUITIES Temporary relief imposes, at most, delay on respondents; denial imposes permanent loss on Applicant and undermines federal protections. The equities favor a stay. IV. PUBLIC INTEREST Preserving federal jurisdiction and uniform application of federal bankruptcy protections serves the public interest and safeguards this Court’s review. RELIEF REQUESTED Applicant respectfully requests that the Chief Justice: 1. Stay enforcement of state-court possession and contempt orders concerning the property at issue pending disposition of the accompanying Rule 20 extraordinary-writ proceeding; or 2. Alternatively, refer this Application to the Court for disposition. ATTACHMENTS REQUIRED BY RULE 23.3 Pursuant to Rule 23.3, Applicant appends the orders and denials relevant to this Application. These materials are contained in the Joint