Whether the Eighth Circuit's summary judgment ruling contravenes Supreme Court precedents governing employment discrimination claims under Title VII and the Arkansas Civil Rights Act

No question identified. : December 8, 2025. Consistent with Rule 13(5), this application is being filed more than 10 days before that date. In support of this request, Applicants state as follows: 1. The opinion and judgment of the United States Court of Appeals for the Eighth Circuit were issued on September 9, 2025 (Exhibit 1). This Court has jurisdiction pursuant to 28 U.S.C. §1254(1). 2. This case involves important federal and constitutional questions. Applicants brought a civil action detailing racial discrimination, retaliation and a hostile work environment at Respondent Nucor Corporation and sought relief for equal protection violations under the Arkansas Civil Rights Act of 1993 which requires the same legal analysis as claims brought under Title VII. Applicants Rod Warren and Eric Booker, African American men, were the victims of overt and systemic racial discrimination at their place of employment, Respondent Nucor Corporation. Mr. Warren alleges that he was subjected to a racially hostile work environment and was fired for being outspoken about the racist atmosphere. He was then falsely accused by a white co-worker of using a racial slur and Nucor attempted to pressure another employee to substantiate this false claim. This white co-worker was promoted while that false accusation was used as a springboard for Mr. Warren’s termination. Mr. Booker’s supervisor called himself a slavedriver while making a whipping motion over Mr. Booker’s head — a clear inference that Mr. Booker was a slave. These overt racial incidents are just two examples of the hostile work environment at Nucor. After complaining about the racial discrimination at Nucor, both men had their employment records peppered with stale and disputed infractions in violation of Nucor’s policies in order to terminate their employment. Some of these purported infractions occurred over a decade ago. 3. The Eighth Circuit affirmed the District Court’s grant of summary judgment to Respondent Nucor in contravention of this Court’s precedent. The important federal and constitutional issues involved include but are not limited to: whether the decision of the Eighth Circuit is in contravention of the precedent set forth in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973); whether the decision of the Eighth Circuit is in contravention of the precedent set forth in Muldrow v. City of St. Louis, 144 S. Ct. 967 (2024); and whether the decision of the Eighth Circuit is in contravention of the precedent set forth in Reeves v. Sanderson Plumbing Prods., 530 U.S. 133 (2000). 4. Applicants’ counsel, Alexandra C. Siskopoulos, was not the attorney of record in the United States Court of Appeals for the Eighth Circuit as the case was handled by another attorney in the firm who is not licensed in this Court. As such, Applicants’ counsel needs time to review the entire record and fully brief the issues to be presented to this Honorable Court. Moreover, Applicants’ counsel has other substantial obligations. 5. In light of the foregoing, Applicants’ counsel respectfully requests an extension of time to familiarize herself with the relevant materials and to address the complex issues raised by the instant petition. WHEREFORE, for the foregoing reasons, Applicants request that an extension of time of sixty (60) days, to and including February 6, 2026, be granted within which Applicants may file a petition for writ of certiorari. November 20, 2025 Respectfully submitted, /s/ Alexandra C. Siskopoulos Alexandra C. Siskopoulos Counsel for Applicants Siskopoulos Law Firm, LLP 136 Madison Avenue 6th Floor #3007 New York, New York 10016 (646) 942-1798 acs@siskolegal.com