Whether the Due Process Clause requires a state court to provide counsel and ensure full financial disclosure before conducting a dispositive hearing that may adversely impact a pro se litigant's legal rights

No question identified. : EMERGENCY APPLICATION FOR A STAY To the Honorable Justice of the Supreme Court of the United States: I. INTRODUCTION AND EMERGENCY POSTURE Applicant respectfully seeks emergency relief from this Court to stay enforcement of state-court orders entered in violation of mandatory Missouri Supreme Court Rule 68.5. Applicant was compelled to proceed to a dispositive financial hearing without counsel, without access to mandatory financial disclosures, and without the ability to prepare or respond to pending motions. Immediate relief is required to prevent ongoing and irreparable harm. Il. JURISDICTION AND PROCEDURAL POSTURE This Court has jurisdiction to consider this emergency application pursuant to 28 U.S.C. § 2101(f) and Rules 22 and 23 of the Rules of this Court. Applicant seeks temporary relief necessary to preserve the status quo and protect federal constitutional rights while state-court remedies are exhausted or shown to be unavailable. Applicant is proceeding pro se and submits this application in paper form by commercial carrier due to inability to file electronically. Il. FACTUAL BACKGROUND This matter arises from family court proceedings in St. Louis County, Missouri, in which Applicant was compelled to proceed to a dispositive hearing without counsel and without access to his attorney’s file, following the court’s approval of counsel’s withdrawal on the eve of hearing. Applicant sought a stay of proceedings prior to and during the hearing, which was denied, and the court proceeded to rule adversely against him. Applicant has consistently asserted that Respondent has procured and continues to seek financial relief while refusing to comply with Missouri Supreme Court Rule 68.5, which mandates the exchange of financial disclosures before financial motions may be heard. Applicant further asserts that enforcement of the resulting orders is ongoing and that the deprivation of counsel and denial of a stay resulted in violations of due process. IV. RULE 23.3 COMPLIANCE AND UNAVAILABILITY OF STATE-COURT RELIEF This application complies with Rule 23.3 of the Rules of this Court. Applicant has sought the same stay relief in the appropriate state courts and such relief is unavailable. A. Circuit Court Prior to the January 16 hearing, Applicant tendered a written Motion to Stay Proceedings to the Circuit Court of St. Louis County, requesting that enforcement and further hearings be stayed due to unresolved discovery violations and the withdrawal of counsel. The trial court declined to grant a stay and proceeded with the hearing. A filed Motion to Stay Proceedings was later submitted to the circuit court and is included in the