Elhadj Alpha Mahmoud Souare v. Summit County, Ohio

Whether Ohio R.C. § 3123.55(A)—which mandates driver’s license suspension without pre-deprivation notice or hearing—violates the Procedural Due Process Clause of the Fourteenth Amendment under Bell v. Burson, 402 U.S. 535 (1971), and whether the Fourth Circuit’s decision in Stinnie v. Holcomb, 55 F.4th 951 (4th Cir.

(en banc), or the Sixth Circuit's decision in Fowler v. Benson, 924 F.3d 247 (6th Cir. 2019), controls.

Whether a government official's refusal to release core public records, accompanied by the use of law enforcement officers to forcibly eject a citizen seeking to inspect administrative files regarding an erroneous license suspension, constitutes impermissible First Amendment retaliation under 42 U.S.C. § 1983 and a total failure of procedural due process.

Whether this Court should grant full plenary review—or, in the alternative, summary reversal—where the underlying administrative license suspension shares the exact same core state agency record (Ohio Bureau of Motor Vehicles) and written admissions of administrative error across parallel state proceedings, yet remains uncorrected due to procedural bar.

Whether a district court's certification under 28 U.S.C. § 1915(a)(3), combined with an appellate filing fee, may permanently foreclose an indigent civil-rights litigant's access to appellate review of an admitted constitutional error, particularly where the dismissal operates with prejudice to permanently bar the claim.

Whether a government entity’s formal notice of administrative error moots an ongoing due process challenge where the entity continues parallel enforcement actions under the identical core administrative record, resolving the split between the Ninth/D.C. Circuits and the Fifth/Eleventh Circuits under Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., 528 U.S. 167(2000).

Whether this Court should accept the supplemental statement and newly arising evidence—including post­ filing administrative notices, state court orders, and documentation of public records refusals—to establish that the controversy remains live and to prevent a total failure of judicial review.