Mark Anthony Hill v. Jennifer Pell, et al.

Whether the factual allegations Petitioner presented in the original and amended complaints demonstrates that the Defendants’ conduct of concealing material eyewitness evidence is a hindrance or impediment to establishing a complete defense in the State court criminal trial proceeding under the second clause of 42 U.S.C. § 1985(2).

Whether assuming all the factual allegations in the original and amended complaints are true allows the Court to draw the reasonably plausible inferences that at least two of the Defendants had a meeting of the minds and parallel behavior of discriminatory animus that, in any manner, obstructed the guaranteed right to justice in the State court in order to warrant a discovery period to be conducted.

Whether the fundamental rights guarantee that automatically attaches to citizens accused of a crime makes them a member of a protected class for purposes of the ‘class-based animus’ requirement of the second clause of 42 U.S.C. § 1985(2).

Whether heightened “probability” standards for showing ‘facial plausibility’ and ‘racial motivation’ were prejudicially applied at the pleading stage of this civil conspiracy action.