1. Whether the Fifth Circuit 's affirmance of the
district court 's dismissal of ADA and TCHRA claims
for failure to exhaust administrative remedies in a de
ferral state violates due process under the Fifth and
Fourteenth Amendments by imposing overly rigid fil
ing requirements that conflict with Supreme Court
precedents on equitable tolling and dual-filing mech
anisms, creating a circuit split with more lenient in
terpretations in the Ninth and Second Circuits, and
departing from accepted practices in federal disability
law enforcement.

2. Whether lower courts ' reliance on pre-ADAAA
definitions of "disability " (e.g., requiring "significant
restriction " rather than "broad coverage ") constitutes
a legal error and departure from the ADAAA 's statu
tory mandate and Supreme Court guidance in Sutton
v. United Air Lines, Inc., 527 U.S. 471 (1999) and
Toyota Motor Manufacturing, Kentucky, Inc. v. Wil
liams, 534 U.S. 184 (2002), as amended by Congress,
raising an important federal question about uniform
application of federal disability law for untreated
chronic conditions like traumatic brain injury and
PTSD.

3. Whether the Fifth Circuit 's narrow application
of the continuing violation doctrine to discrete acts of
disability discrimination (e.g., failure to accommodate
and wrongful termination) conflicts with National
Railroad Passenger Corp. v. Morgan, 536 U.S. 101
(2002), where ongoing patterns of discrimination
should toll limitations periods, presenting a nation
ally important issue for workers in deferral states suf
fering from cumulative harms.

4. Whether dismissing pro se ADA claims without
considering "regarded as" disabled prongs or liberally
construing pleadings violates equal protection and ac
cess to justice principles, especially when lower courts
legally erred by ignoring the EEOC amicus briefs ar
guments for AD AAA compliance and "regarded as" vi
ability, creating conflicts with this Court 's rulings on
pro se leniency in Haines v. Kerner, 404 U.S. 519
(1972).

5. Whether the Fifth Circuit 's refusal to recognize
a timely March 12, 2022 verified EEOC intake ques
tionnaire as a "charge " under Federal Express v.
Holowecki, 552 U.S. 389 (2008), and Edelman v.
Lynchburg College, 535 U.S. 106 (2002), creates an
acknowledged circuit conflict and warrants this
Court 's review.

Whether the Fifth Circuit's affirmance of dismissal of ADA and TCHRA claims for failure to exhaust administrative remedies violates due process by imposing overly rigid filing requirements that conflict with Supreme Court precedents on equitable tolling, creating a circuit split, and whether lower courts' reliance on pre-ADAAA definitions of disability constitutes legal error departing from statutory mandate and Supreme Court guidance, and whether the Fifth Circuit's narrow application of the continuing violation doctrine conflicts with National Railroad Passenger Corp. v. Morgan, and whether dismissing pro se ADA claims without considering 'regarded as' disabled prongs violates equal protection and access to justice principles, and whether the Fifth Circuit's refusal to recognize a timely EEOC intake questionnaire as a 'charge' creates a circuit conflict warranting review