The history of U.S. Supreme Court decisions demonstrate that a Court of Appeals should grant a pro se plaintiff IFP status, pursuant to 28 U.S.C, §1915(a), and should give said pro se litigant the right to be heard, just like a paying litigant, whenever meritorious issues are presented for review on appeal. Although I presented such questions on appeal, including a constitutional challenge to the interpretation of 42 U.S.C. §1981, the United States Court of Appeals for the Second Circuit declined to exercise jurisdiction over my appeal by dismissing it, pursuant to 28 U.S.C. §1915(e), without full briefings from all parties. This was an appeal based on racially motivated violence and intimidation in the workplace that was fully condoned by my former employer Alliance Nursing Staffing of New York, Inc. (Alliance) for years prior to the incidents described in my complaint to the United States District Court for the Southern District of New York.

The following questions are presented:

1. Whether the Second Circuit erred in dismissing my question on appeal that 42 U.S.C. §1981 protects against the deprivation of the security of person and property in the enforcement of contracts, whether or not race is a factor, pursuant to the Ninth, the Thirteenth, and the Fourteenth Amendments to the U.S. Constitution, which is an important question of federal law that has not been, but should be, settled by the U.S. Supreme Court, and is an important federal question decided by the Second Circuit in a way that conflicts with Students for Fair Admissions, Inc. v. Hopkins, 118 U.S. 356 (1886), along with other relevant decisions by the U.S. Supreme Court.

2. Whether the Second Circuit erred in dismissing my question on appeal that the term "all persons" under 42 U.S.C. §1981, which was adopted from Part I of Section I of the Fourteenth Amendment, makes a claim for violation of civil rights because of one's 'national origin' cognizable under this statute, whether or not race is a factor, which is an important question of federal law that has not been, but should be, settled by the U.S. Supreme Court, and is an important federal question decided by the Second Circuit in a way that conflicts with Yick Wo v. Hopkins, 118 U.S. 356 (1886), along with other relevant decisions by the U.S. Supreme Court.

3. If 42 U.S.C. §1981 covers issues other than "color or race", and considering that Section II of the Civil Rights Act of 1866 cites "involuntary servitude" (deprivation of the security of person and property - race not necessary under the Thirteenth Amendment) or "color and race" as impermissible purposes to violate a person's civil rights, whether the "but for race" standard established under Comcast Corp. v. Nat'l Ass'n of African Am. Owned Media, 140 S. Ct. 1009, 206 L. Ed. 2d 356 (2020) is still good law and whether this standard is unconstitutional pursuant to the Thirteenth and Fourteenth Amendments to the U.S. Constitution as these parent constitutional amendments to §1981 require race neutrality, which is an important question of federal law that has not been, but should be, settled by the U.S. Supreme Court.

4. Whether the term "proceedings" under 42

Whether the Second Circuit erred in dismissing a pro se litigant's appeal challenging the interpretation of 42 U.S.C. §1981 and the right to be heard