Ezequiel Rivera v. Nestle USA, Inc.

is: Whether federal courts violate Haines v. Kerner and create a de facto circuit split by narrowly construing pro se EEOC charges to include only checked boxes rather than the factual narrative supplied, thereby barring hostile-environment and retaliation claims that arise directly from the pro se complainant’s written description of events. Question 2 — Spoliation under Rule 37(e) When Employers Control the Only Evidence (Video + Contemporaneous Notes) The question presented is: Whether Rule 37(e) permits courts to require direct evidence of bad faith before granting any spoliation remedy, even when an employer destroys the only video and contemporaneous investigative notes relevant to a Title VH claim, or whether circumstantial evidence of intent—recognized by multiple circuits—is sufficient to warrant sanctions or adverse inferences. Question 3 — Summary Judgment, the Honest-Belief Doctrine, and Conflict with Reeves and Anderson The question presented is: Whether the “honest belief” doctrine permits courts to grant summary judgment to employers by crediting their stated rationale despite conflicting evidence, destroyed records, and factual disputes, contrary to Reeves and Anderson, which require that all reasonable inferences favor the nonmovant and prohibit credibility weighing at summary judgment. Question 4 — Access to Courts for Pro Se Title VH Litigants: Discovery Denials, Motion Restrictions, and Premature Judgment The question presented is: Whether federal courts must ensure meaningful access to justice for pro se Title VII litigants—by allowing reasonable discovery, liberally construing pleadings, and applying summary-judgment standards faithfully—or whether courts may impose heightened procedural hurdles (including restricting motions, denying discovery, and accepting employer-controlled evidence) that effectively preclude pro se civil-rights plaintiffs from reaching a jury trial.