Whether 28 U.S.C. § 1443(1) permits removal to federal court for civil rights protections based on disability when a litigant alleges inability to enforce ADA rights in state court

No question identified. : mandate issuing and within the timeframe for filing a Petition for Writ of Certiorari, which is due no later than March 11, 2026. Ill. BACKGROUND Petitioner is a pro se litigant with a documented disability who removed her state court proceeding to federal court under 28 U.S.C. § 1443(1), alleging structural discrimination and ADA exclusion by state court actors. The district court remanded, and the Tenth Circuit affirmed. However, the Tenth Circuit: e Did not rule on Petitioner’s properly filed Motion for Panel Review of Fraud Upon the Court (Dkt. 35); e Denied all pending emergency motions, including requests for protection, without reasoned opinion; e Denied Petitioner’s motion to stay the mandate, despite her active pursuit of certiorari and preservation of her federal rights. ses abit fsa a Petitioner now seeks to preserve jurisdiction and halt the issuance of the Tenth Circuit’s mandate to prevent resumption of state court proceedings that threaten her parental rights, access to justice, and protected ADA interests. IV. REASONS FOR GRANTING THE STAY A. There is a Reasonable Probability of Certiorari Being Granted Petitioner’s forthcoming petition raises questions of first impression under 28 U.S.C. § 1443(1): whether civil rights protections based on disability under the ADA qualify as laws "providing for equal civil rights" entitling temoval when a litigant cannot enforce those rights in state court. Additionally, Petitioner raises due process concerns arising from the Tenth Circuit's failure to adjudicate her fraud and emergency motions, and the denial of relief without reasoned explanation. These unresolved questions require this Court’s supervisory guidance. B. Petitioner Will Suffer Irreparable Harm Without a Stay If the mandate issues, Petitioner faces immediate and irreparable harm, including: _ e Resumption of state court proceedings without jurisdiction; e Continued denial of ADA accommodations and access to meaningful participation; e Risk of permanent alienation from her child due to unlawful state action. The relief requested is narrowly tailored to maintain the status quo while certiorari is pursued. C. No Hamm to Respondent Respondent has defaulted in the federal proceedings and has not participated in the appellate litigation. There is no demonstrable prejudice to Respondent if a stay is granted. D. Public Interest Favors the Stay The case presents recurring issues of national importance regarding the rights of disabled litigants to access federal courts, the proper scope of § 1443(1), and the integrity of judicial proceedings. Granting the stay would promote respect for federal constitutional protections and ~ protect vulnerable litigants from irreparable injury. V. CONCLUSION Petitioner respectfully requests that the Circuit Justice grant this Emergency Application for Stay of the Mandate pending the timely filing and disposition of a Petition for Writ of Certiorari. Respectfully submitted, December 16, 2025 /s/ Angeliina Lynn Lawson. Angeliina Lynn Lawson, Pro Se 1914 5th Avenue, Leavenworth, KS 66048 CERTIFICATE OF SERVICE I hereby certify that on December 16, 2025, a true and correct copy of the foregoing Emergency Application for Stay Pending Certiorari was served via clerk’s filing system to all parties. /s/ Angeliina Lynn Lawson Pro Se Applicant | ANGELINA LAWSON 10 EBs 1 OF 1 HP WT: 10 LBS THE UPS STORE#646; Dare: 17 bee 2026 Tipe kangas oh BOA LANSING Ko 66043-1616 a ae ta SHIP OF THE UNITED STATES » TO: GE RK QF THE SUPREME .COURT 1ST ST NE MMZGHBSQNEHFN ISH 13.000 BIXOLON 8 40.8V 11/2025 PepRunarx fe Appellate Case: 25-3097 Document: 59-1 _ Date Filed: 12/11/2025 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit FOR THE TENTH CIRCUIT December 11, 2025 Christopher M. Wolpert JONATHAN DAVID LAWSON, —eow Plaintiff Appellee, v. No. 25-3097 (D.C. No. ANGELIINA LYNN LAWSON, (D. Kan.) Defendant Appellant. ORDER AND JUDGMENT“ Before