In Re Rayon Payne

Whether a United States District Court may transfer a case under 28 U.S.C. § 1404(a) to a judicial district where the Plaintiff has already demonstrated and documented structural bias and ongoing constitutional violations, thereby denying meaningful access to judicial remedies.

Whether it violates the Due Process Clause of the Fifth Amendment for a District Court to allow the government to review the Plaintiff’s immigration file—used as the basis for its dispositive motion—while denying the Plaintiff access to the same records, and subsequently ruling on the government’s motion.

Whether a District Court may sidestep its statutory responsibility under 8 U.S.C. § 1447(b) by transferring the case after acknowledging jurisdiction and after the Plaintiff invoked that provision to compel action on a naturalization application.

Whether a litigant is entitled to relief where the District Court closes the case while simultaneously placing the Plaintiff in procedural limbo by transferring the matter into a structurally compromised judicial district and circuit, thereby leaving no viable judicial forum for redress.