Aura Moody, on Behalf of Her Minor Child, J. M. v. National Football League

This Petition for a Writ of Certiorari gives this Court an opportunity to decide important questions of deferral law regarding statutory standing doctrine in the context of a claim that is based on constitutional rights violations. The questions presented below are essential and deserve the Supreme Court of the United States’ attention. The questions for this Court are:

1. WHETHER THE COURT OF APPEALS HAD THE AUTHORITY TO DISMISS THE APPEAL BECAUSE IT ALLEGEDLY “LACKS AN ARGUABLE BASIS EITHER IN LAW OR IN FACT” WITHOUT GIVING PETITIONER THE OPPORTUNITY TO PRESENT HER EVIDENCE AND BE HEARD ON THE ISSUES PRESENTED TO THEM FOR REVIEW ON THE MERITS, WITHOUT ENFORCING RESPONDENT’S COMPLIANCE WITH FEDERAL RULES OF APPELATE PROCEDURE (“FRAP”) AND COURT’S LOCAL RULES (“LOCAL RULES”); AND WHETHER THESE ISSUES WERE PROPERLY ADDRESSED BY THE COURT PRIOR TO RENDERING ITS DECISION?

2. WHETHER THE COURT OF APPEALS’ JUDGEMENT IS PROCEDURALLY DEFICIENT AND CONSTITUTIONALLY INVALID SINCE IT DENIED PETITIONER’S MOTION FOR LEAVE TO AMEND THE CAPTION OF THE CASE, ADD PARTIES, SUPPLEMENT THE PLEADINGS, COMPELL THE DISCLOSURE-PRODUCTION OF DOCUMENTS AND RELIEF FROM JUDGMENT-ORDER (“MOTION FOR LEAVE TO AMEND”) OVERLOOKING THE FACT THAT RESPONDENT DID NOT FILE AND SERVE A RESPONSE TO THE MOTION IN DISREGARD OF FRAP AND LOCAL RULES, AND THE COURT FAILED TO DEMAND A RESPONSE; WHETHER THE COURT MISCARRIAGED JUSTICE BY NOT RENDERING A TIMELY DECISION ON THE MOTION; AND WHETHER THESE ISSUES WERE PROPERLY ADDRESSED BY THE COURT PRIOR TO ITS DECISION ON PETITIONER’S MOTION?

3. WHETHER THE DISTRICT COURT’S JUDGEMENT IS PROCEDURALLY DEFICIENT AND CONSTITUTIONALLY INVALID SINCE IT DENIED PETITIONER’S MOTION TO VACATE JUDGMENT, INTRODUCE NEW EVIDENCE AND REOPEN THE CASE (“MOTION TO VACATE THE JUDGMENT”) WITHOUT AFFORDING HER AN OPPORTUNITY TO BE HEARD ON THE ISSUES PRESENTED TO THEM FOR REVIEW ON THE MERITS AND RECEIVING RESPONDENT’S ANSWER TO THE MOTION; WHETHER THE COURT FAILED TO ORDER A DEFAULT JUDGMENT GIVEN RESPONDENT’S NON-COMPLIANCE WITH FEDERAL RULES OF CIVIL PROCEDURE (“FRCP”) AND LOCAL RULES; WHETHER THE COURT FAILED TO ENFORCE COMPLIANCE WITH FRCP AND LOCAL RULES BY NOT DEMANDING RESPONDENT’S ANSWER AND IMPOSING SANCTIONS FOR SUCH VIOLATIONS; WHETHER THESE ISSUES WERE ADDRESSED BY THE DISTRICT COURT PRIOR TO RENDERING ITS DECISION; AND WHETHER THESE ISSUES WERE PROPERLY REVIEWED AND ADDRESSED BY THE CIRCUIT COURT ON APPEAL? 4. WHETHER THE COURT OF APPEALS’ JUDGMENT IS PROCEDURALLY DEFICIENT AND CONSTITUTIONALLY INVALID AS IT OVERLOOKED THE FACT THAT RESPONDENT DID NOT FILE AND SERVE THE ACKNOWLEDGMENT AND NOTICE OF APPEARANCE FORM IN DISREGARD OF FRAP AND LOCAL RULES; WHETHER THE COURT FAILED TO ENFORCE COMPLIANCE WITH FRAP AND LOCAL RULES BY NOT DEMANDING RESPONDENT’S ANSWER AND IMPOSING SANCTIONS FOR SUCH VIOLATIONS; AND WHETHER THESE ISSUES WERE PROPERLY ADDRESSED BY THE COURT PRIOR TO RENDERING ITS JUDGMENT?

4. WHETHER THE COURT OF APPEALS’ JUDGMENT IS PROCEDURALLY DEFICIENT AND CONSTITUTIONALLY INVALID SINCE IT OVERLOOKED THE FACT THAT RESPONDENT DID NOT FILE AND SERVE A BRIEFING SCHEDULE; WHETHER THE COURT FAILED TO ENFORCE COMPLIANCE WITH FRAP AND LOCAL RULES BY NOT DEMANDING RESPONDENT’S ANSWER AND IMPOSING SANCTIONS FOR SUCH VIOLATIONS; AND WHETHER THESE ISSUES WERE PROPERLY ADDRESSED BY THE COURT PRIOR TO RENDERING ITS DECISION?

5. WHETHER THE COURT OF APPEALS’ JUDGEMENT IS PROCEDURALLY DEFICIENT AND CONSTITUTIONALLY INVALID AS IT OVERLOOKED THE FACT THAT RESPONDENT DID NOT FILE AND SERVE A RESPONSE BRIEF AND APPENDIX; WHETHER THE COURT FAILED TO ENFORCE COMPLIANCE WITH FRAP AND LOCAL RULES BY NOT DEMANDING in RESPONDENT’S ANSWER AND IMPOSING SANCTIONS FOR SUCH VIOLATIONS; AND WHETHER THESE ISSUES WERE PROPERLY ADDRESSED BY THE COURT PRIOR TO RENDERING ITS DECISION?

6. WHETHER THE DISTRICT COURT’S JUDGMENT IS PROCEDURALLY DEFICIENT AND CONSTITUTIONALLY INVALID AS IT OVERLOOKED THE FACT THAT PETITIONER HAS ASSERTED HER OWN MERITORIOUS CLAIMS (DIFFERENT FROM JULIAN’S) IN PARAGRAPH “22” OF THE AMENDED COMPLAINT, AND THAT HER INDIVIDUAL CLAIMS WERE NOT RESOLVED BEFORE THE CASE WAS CLOSED; WHETHER THE COURT ADDRESSED THE IMPROPER REMOVAL OF PETITIONER’S NAME FROM THE CAPTION OF THE CASE, WITHOUT CONSENT AND NOTIFICATION, ALTHOUGH SHE ALERTED THE COURT ABOUT SUCH A IRREGULARITY; WHETHER THE COURT OVERLOOKED THE FACT THAT NEITHER PETITIONER NOR HER SON JULIAN MOODY SOUGHT REMOVAL OF HER NAME FROM THE AMENDED COMPLAINT; WHETHER THESE ISSUES WERE REVIEWED AND ADDRESSED BY THE COURT PRIOR TO RENDERING ITS DECISION ON PETITIONER’S MOTION TO VACATE THE JUDGMENT; AND WHETHER THESE ISSUES WERE PROPERLY ADDRESSED BY THE CIRCUIT COURT ON APPEAL?

7. WHETHER THE COURT OF APPEALS’ JUDGMENT IS PROCEDURALLY DEFICIENT AND CONSTITUTIONALLY INVALID AS IT OVERLOOKED THE FACT THAT THE DISTRICT COURT DEPARTED FROM THE ESSENTIAL