Sarai Hannah Ajai v. North Dakota Department of Transportation, et al.

Petitioner, a pro se civil-rights litigant, challenges the ongoing alteration and redistribution of her state-issued North Dakota REAL ID identification cards and identity records. The lower courts dismissed on Rule 4(m) and sovereign-immunity grounds without reaching her constitutional claims.

1. Rule 4(m) / pro se I actual notice. Whether a district court abuses its discretion by dismissing a pro se civil-rights action under Federal Rule of Civil Procedure 4(m) despite diligent service efforts, and despite respondents’ actual notice and no showing of prejudice, where the district court neither grants additional time nor directs reasonable alternative service, and without otherwise assisting the pro se litigant facing complex multi-sovereign service rules.

2. Eleventh Amendment / Ex parte Young. Whether the Eleventh Amendment bars a pro se litigant’s suit seeking prospective injunctive relief to halt the ongoing misuse and alteration of state-issued identification cards and identity records where the pleadings invoked Ex parte Young and alleged continuing violations of federal constitutional rights, but the lower courts dismissed on sovereign-immunity grounds without addressing that doctrine or allowing amendment to name the responsible state officers.

3. REAL ID / constitutional violations. Whether a State’s alteration or redistribution of state-issued REAL-ID driver’s-license cards and finked identity records without notice or judicial process violates the Fourteenth Amendment’s Due Process and Equal Protection Clauses; whether federal actors’ manipulation of those records and the warrantless interception or seizure of the Petitioner’s sealed mail violates the Fourth and/or Fifth Amendments; and whether those practices, insofar as they compel Petitioner’s identity-related services or associations, implicate the Thirteenth Amendment.