1. Whether an undocumented immigran t like Javier Perez, who came to
the United States over 15 years ago and de veloped substantial ties to this country
during that time, is among "the people" who possess the "inherent" and"preexisting" right of armed self-defense codified in the Second Amendment,
District of Columbia v. Heller
, 554 U.S. 570, 628 (2008), a question on which the
Circuits are split.

2. Whether the Second Circuit flouted Heller by reviewing the
constitutionality of 18 U.S.C. § 922(g)(5 ), barring undocumented immigrants from
possessing a firearm in any circumstance, under a deferential "interest-balancing"test and then by upholding the law despite acknowledging its substantial
overbreadth and lack of empirical basis. Al ternatively, whether this petition should
be held pending the Court's decision in New York State Rifle & Pistol Association v.
Bruen , No. 20-843 (argument set for November 3, 2021), raising the same complaint
concerning the Second Circuit's review (and upholding) of a New York law barringpersons from publicly carrying firearms.

Whether undocumented-immigrants have 2nd-amendment-rights