Richard Wershe, Jr. v. City of Detroit, Michigan, et al.

Does the two-factor equitable tolling test supplied by this Court in Holland v. Florida, 560 U.S. 631, 649 (2010) apply to all federal equitable tolling cases, all prisoner cases, or only habeas cases, and was the Sixth Circuit correct to reject it in favor of its own five-factor test in Zappone v. United States, 870 F.3d 551, 559 (6th Cir. 2017)?

Should this Court formalize and standardize the emerging ‘prisoner-fear-of-retaliation doctrine’ among the circuits, which is available in other circuits but which the Sixth Circuit declined to adopt?

Is review required to clarify the distinction between the federal equitable tolling doctrine and equitable estoppel doctrine, where both lower courts applied the ‘estoppel’ requirement that a defendant be the cause of Petitioner’s extraordinary circumstances (i.e., his fear of retaliation) to warrant equitable tolling?

Did the lower courts err requiring review in ruling that diligence is lacking, where, upon a prisoner’s release from prison after 32 years, he promptly found an attorney, began working with said attorney to bring his claims, and brought said claims the day before his one-year probationary release period had ended (to ensure those he feared could not falsely convict him, which would his life sentence)?