Neil McNaughton v. Eric Adams, Mayor of the City of New York, et al.

This is petitioner’s attempt to address through le' gabaction persistent harassment by the New York City Police Department (“NYPD”) and others that was started in response to false allegations made to the police by petitioner’s mentally ill sister, now deceased, and that has been occurring in New York City since the summer of 2011. As is set forth more fully below, this is petitioner’s second such attempt. These are the ques­ tions presented in this petition:

1. As demonstrated by the rulings of the district court and the circuit court in this action and in a prior related action, does the persistent misapplication of the Twombly plausibility test by Federal judges invar­ iably lead to a violation of this Court’s mandate in Erickson v. Pardus regarding the proper judicial treat­ ment of well pleaded factual allegations?

2. Does the repeated failure of the presiding judges herein and in a prior related action to accurately describe the factual predicates and claims contained in the pro se petitioner’s complaint constitute an issue that needs to be specifically addressed by this Court?

3. Should the use of memorandum opinions and summary orders by members of the Federal judiciary be sharply curtailed because of its tendency to pro­ mote and sanitize irrational reasoning and shoddy ju­ risprudence, and in furtherance thereof should this Court issue clear guidelines regarding the appropriate employment of these widespread violations of judicial accountability?