Eric J. Mapes v. Indiana, et al.

Whether a federal court of appeals may, consistent with the First Amendment right to petition and the Fifth Amendment guarantee of due process, effectively bar an indigent, disabled litigant from all appellate review of substantial constitutional claims by denying in forma pauperis status and requiring full prepayment of fees—where the litigant cannot pay without sacrificing basic necessities including food, housing, utilities, transportation to chemotherapy, and prescription medications—and in conflict with this Court’s decisions in Griffin v. Illinois, 351 U.S. 12 (1956), Boddie v. Connecticut, 401 U.S. 371 (1971), and M.L.B. v. S.L.J., 519 U.S. 102 (1996).

Whether Indiana may, consistent with the Full Faith and Credit Clause, impose lifetime registration as a "serious sex offender" based on a Texas conviction under Tex. Penal Code § 22.011(a)(1)—an adult-only offense without age-based elements or SVP designation—when Indiana's "serious sex offender" classification under Ind. Code § 35-42-4-14 requires either age­ based elements or SVP status, thereby altering the fundamental nature of the Texas conviction.

Whether Indiana may, consistent with the Ex Post Facto Clause and Due Process Clause, impose lifetime registration requirements when: (a) Indiana's own statutory scheme under Ind. Code § ll-8-8-19(a) establishes a default ten-year registration period; (b) the Indiana Supreme Court in Peters v. Quakenbush, N.E.3d , 2025 WL 3087540 (Ind. June 19, 2025) held that registration obligations apply only when a person "is"—present tense—required to register in another jurisdiction; and (c) both the convicting state (Texas) and the state of last residence (Alaska) have determined Petitioner has no current registration duty.

Whether Indiana may, consistent with the constitutional right to travel, create a "registration orphan" status by imposing lifetime burdens based on a conviction for which no current registration duty exists in any jurisdiction—where Texas (convicting state) imposes no duty because Petitioner does not reside there, and Alaska (state of last residence) affirmatively removed Petitioner's registration duty on January 18, 2023 review.

Whether Indiana courts may violate the Americans with Disabilities Act and Rehabilitation Act by: (a) refusing disability accommodations for Petitioner's neurological voice disorder; (b) characterizing Petitioner as "alleging to be disabled" despite possessing official Social Security Administration disability records; and (c) using Petitioner's disability status to justify mistreatment and denial of meaningful access to the courts.

Whether Indiana courts may retaliate against a litigant's First Amendment right to petition for redress of grievances by labeling protected constitutional litigation as "frivolous," "abusive," and "vexatious" solely because the litigant exercises the right to challenge ongoing constitutional violations.