Cassandra Perkins v. United States District Court for the Northern District of Georgia, et al.

Whether a district court judgment dismissing Petitioner's claims under the Americans with Disabilities Act, 42 U.S.C. §§ 12101 et seq. (Titles I and V), and Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2oooe-2(a)(i)(2) and 2oooe-2(c)(i), against a major healthcare conglomerate and its staffing agency intermediary must be vacated where: (I) The magistrate judge who issued the Report and Recommendation underlying all dispositive rulings subsequently self-recused for pecuniary interest under 28 U.S.C. § 455(b)(4), rendering the R&R constitutionally void at inception and tainting every ruling built upon it; (II) The district judge who adopted the tainted R&R - stripping Petitioner's remedies across ADA Titles I and V and Title VII simultaneously, including the anti-retaliation protections of 42 U.S.C. § 12203 — has since been elevated to Chief Judge of the Eleventh Circuit, creating an unremedied structural conflict now embedded in the circuit's own judicial conduct oversight machinery under 28 U.S.C. §§ 351-364; (III) The Eleventh Circuit denied appeal and subsequently issued a Rule 60 remand to the same district court where the tainted adoption remained uncorrected, and where dismissal on procedural technicality — rather than merits review — completed the foreclosure of a fully exhausted, EEOC-predicated civil rights complaint in violation of the Fifth Amendment's due process guarantee; and (IV) The cumulative effect - tainted adjudication, dual-respondent liability foreclosure across two federal civil rights frameworks, procedural shell game between circuit and district courts, and structural entrenchment of the conflicted judicial officer — represents a pattern of systemic bias against a pro se civil rights plaintiff that implicates the integrity of civil rights enforcement across the Eleventh Circuit and warrants this Court's supervisory review. (V) Whether the ongoing coordinated retaliation 18 U.S.C. § 241, against Petitioner through employment and professional circumstances following judicial foreclosure of her civil rights claims — previously raised in lower court filings and construed under Erickson v. Pardus, 551 U.S. 89 (2007) — constitutes a continuing violation that this Court must address to prevent irreparable harm to a pro se litigant whose ability to communicate, correspond, and access the courts is presently imperiled by the same actors whose conduct is the subject of this petition. (VI) Whether a pro se plaintiff with a qualifying disability under the ADA suffers irreparable constitutional harm — cognizable under ADA Title V, 42 U.S.C. § 12203, and the Due Process Clause of the Fifth Amendment — when a federal tribunal acknowledges the legal sufficiency of her disability-related disclosures and claims only to invoke those same disclosures in the same ruling to strip her Title remedies, creating an internal judicial contradiction that transforms good-faith litigation participation into the instrument of her own foreclosure, and inflicting compounded psychological harm on a litigant whose disability made her particularly vulnerable to precisely that form of institutional betrayal 18 U.S.C. § 241 federal "Conspiracy Against Rights"; and whether such conduct by a tribunal constitutes a discrete and continuing violation of the anti-retaliation mandate of 42 U.S.C. § 12203 that this Court has never addressed. Subsidiary Question: Whether a pro se civil rights plaintiff who properly exhausted administrative remedies before the EEOC, timely objected to a magistrate's recommendations, and preserved all claims through the appellate process is denied meaningful access to federal civil rights enforcement when the entire adjudicative chain from R&R through adoption through appellate review is structurally compromised by an unrecused and subsequently self-recused judicial officer whose pecuniary interest ran to the respondents.