Petitioner, a US citizen, was deprived of the granny flat in his home by a board where the city had a 99.4% win rate. Review was by appeal only. The city pays a pension to appellate judge. Disqualification was denied. Administrative order received one-word affirmance. 4 unexplained dispositions followed. Pro se briefs were respectful and motivated: Petitioner, a shy Harvard MBA graduate [GMAT entry test 760 vs. 708 class average], and foreign-trained attorney, had studied intensively in a Jesuit law school in Spain.

Local entities and FDR share regulatory nature. An entity can also be as aggressive to a lower court as FDR was to this Court. In 1816 Jefferson noticed that lower courts lack protections: He was not amused.

The questions presented are:

1. Whether the "appellate review model " is contrary to evidentiary standard protections, one of them being Addington v. Texas , 441 U.S. 418 (1979).

2. Whether elaborated dispositions in non-en banc courts are a substantive due process protection.

3. Whether preponderance of the evidence is insufficient standard in civil enforcement.

4. Whether Brady v. Maryland , 373 U.S. 83 (1963) applies to civil enforcement.

5. Whether a private party retains one peremptory disqualification in non-era banc courts.

6. Whether judges hold office during good behavior.

7. Whether State Supreme Court 's discretionary jurisdiction is a substantive due process protection.

Whether the 'appellate review model' is contrary to evidentiary standard protections