Whether an attorney's advocacy in opposing disability accommodations can constitute discrimination or retaliation under the Americans with Disabilities Act

No question identified. : To the Honorable Brett M. Kavanaugh, Associate Justice of the Supreme Court of the United States and Circuit Justice for the Sixth Circuit: Petitioner Teresa Maria Harmon, pro se, prays for a 60-day extension of time, Pursuant to Rule 13.5 of the Rules of this Court, to and including December 13, 2025, in which to file a petition for a writ of certiorari. In support of this request, Petitioner states as follows: 1. On June 6, 2025, the United States Court of Appeals for the Sixth Circuit affirmed the judgment dismissing Petitioner’s case under the Americans with Disabilities Act. Petitioner timely filed a petition for rehearing en banc, which was denied on July 16, 2025. The mandate issued on July 24, 2025. 2. Petitioner has ninety days from July 16, 2025, to file a petition for a writ of certiorari. See Sup. Ct. R. 13.3. The petition is, therefore, due on October 14, 2025. This application is being filed at least ten days before that date. 3. The jurisdiction of this Court is invoked under 28 U.S.C. § 1254(1). 4, This case raises important questions regarding the scope of Titles I, HI, and V of the Americans with Disabilities Act, including whether opposing counsel may avoid liability for discrimination, interference, or retaliation under the guise of “zealous advocacy” when Congress made no such exception. 5, An extension is warranted to allow sufficient time to research circuit conflicts (including Post v. Trinity Health-Michigan, 44 F.4t 572 (6t» Cir. 2022); Binno v. Am. Bar Ass’n, 826 F.3d 338 (6t Cir. 2016); and PGA Tour, Inc. v. Martin, 532 U.S. 661 (2001)), to prepare the petition carefully, and to consult with potential amici. 6. Petitioner believes an extension of time will be needed to adequately prepare Petitioner’s petition for writ of certiorari. Petitioner is proceeding pro se and requires additional time due to limited resources, disability, and ongoing health concerns. This is Petitioner’s first request for an extension. KEK WHEREFORE, Petitioner respectfully requests that an order be entered extending her time in which to petition for certiorari by sixty days, to and including December 13, 2025. Teresa Maria Harmon Petitioner, pro se 235 N. Burkhardt Rd., 1097 Evansville, Indiana 47715 (225) 335-3151, Dated: September 16, 2025 Case: 24-5773 Document: 22-1 Filed: 06/06/2025 Page: 1 NOT RECOMMENDED FOR PUBLICATION No. 24-5773 FILED Jun 6, 2025 UNITED STATES COURT OF APPEALS ; FOR THE SIXTH CIRCUIT KELLY L. STEPHENS, Clerk TERESA M. HARMON, ) ) ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE WESTERN DISTRICT OF LOUIS I. WATERMAN; GOLDBERG SIMPSON, ) KENTUCKY LLC, ) ) ) Before: GIBBONS, BUSH, and DAVIS, Circuit Judges. Teresa M. Harmon, proceeding pro se, appeals the district court’s judgment dismissing her complaint of discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. § 12101, et seq. She also requests oral argument. This case has been referred to a panel of the court that, upon examination, unanimously agrees that oral argument is not needed. See Fed. R. App. P. 34(a). Because Harmon failed to state a claim under the ADA, we affirm. Harmon sued an attorney, Louis I. Waterman, and a law firm, Goldberg Simpson, LLC, who represent her ex-husband in their divorce and child-custody proceedings. She claimed that the defendants violated the ADA by opposing her attempts to obtain disability accommodations from a state court. Because we review this case on a motion to dismiss, we recount the facts as they are alleged in the complaint and view them in the light most favorable to the plaintiff. Christopher v. Harbury, 536 U.S. 403, 406 (2002). Harmon alleged that the defendants began representing her ex-husband in 2010 and long argued that she suffered from an undiagnosed psychiatric disorder as a way to gain an advantage Case: 24-5773 Document: 22-1 Filed: 06/06/2025 Page: 2 No. 24-5773 -2in those proceedings. In 2021, Waterman, on his client’s b