Jayne Swinford v. Officer Joshua Santos, et al.
1. Seventh Amendment and Due Process:
Whether the lower courts violated the Seventh
Amendment's guarantee of a jury trial and the Fifth
Amendment's Due Process Clause by dismissing
Petitioner's civil rights action at the pleading stage based
on their own interpretation of video evidence, thereby
resolving factual disputes that should have been reserved
for a jury, in direct conflict with this Court's reaffirmation
of the right to a jury trialin SEC v. Jarkesy, 603 U.S. 109
(2024).
2. Violation of Federal Procedural Rules:
Whether the lower courts' failure to adhere to the
Federal Rules of Civil Procedure—by treating extrinsic
video footage as part of the pleadings (contrary to Rule
10(©"'s limitation to "written instruments"), considering
matters outside the complaint without converting the
motion to summary judgment (in defiance of Rule 12(d)),
and effectively granting judgment as a matter of law
despite genuine disputes of material fact (undercutting
the standards of Rule 56)—deprived Petitioner of the
procedural safeguards and fair process that due process
and the Rules are designed to protect.
Each question presents an unaddressed but
fundamental constitutional conflict: can courts deprive
a plaintiff of her day in court and jury trial by shortcircuiting established procedure, and will this Court
permit the erosion of Seventh Amendment and due process
protections under the guise of qualified immunity and
judicial efficiency?
Whether the lower courts violated the Seventh Amendment's guarantee of a jury trial and the Fifth Amendment's Due Process Clause by dismissing Petitioner's civil rights action at the pleading stage