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RSBCO v. United States

Paid petition · United States Court of Appeals for the Fifth Circuit, No. 23-30062 · judgment June 13, 2024


Certiorari denied · January 13, 2025
Pre-decision estimate: 1% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

  1. “Invited Error” Violation. Did the Fifth Circuit err by reversing because of jury instructions that the Government itself drafted?

  2. United Dominion Violation. Did the Fifth Circuit err by interpreting an undefined and unlimited term (“Impediment”) in favor of the IRS and against the taxpayer?

  3. Neder Violation. Did the Fifth Circuit err by reversing because of jury instructions when overwhelming evidence would have supported the same result with different jury instructions?

  4. Rule 51 Violations. Did the Fifth Circuit err by reversing because of a: (1) jury instruction that the Government never objected to at trial; and/or (2) verdict form that the Government never objected to at trial?

  5. Attorney Fee Award. If the Fifth Circuit erred for any of the reasons stated above, did it then also err by vacating the attorney fee award for RSBCO?

Counsel of record

For petitioner
Russell Alan Woodard Jr.
Law Offices of Russell A. Woodard, Jr. LLC

For respondent
Elizabeth B. Prelogar
Solicitor General

Case

Conference history
Distributed for 1 conference

Linked docket
24A305

Proceedings

  1. Jan 13 2025
    Petition DENIED.
  2. Dec 04 2024
    DISTRIBUTED for Conference of 1/10/2025.
  3. Nov 29 2024
    Waiver of right of respondent United States to respond filed.
  4. Oct 17 2024
    Petition for a writ of certiorari filed. (Response due December 19, 2024)
  5. Sep 30 2024
    Application (24A305) granted by Justice Alito extending the time to file until October 22, 2024.
  6. Sep 26 2024
    Application (24A305) to extend the time to file a petition for a writ of certiorari from October 7, 2024 to October 22, 2024, submitted to Justice Alito.