1. Whether a district court may grant summary judgment without affording any opportunity for discovery —contrary to Celotex Corp. v. Catrett, 477 U.S. 317 (1986) —where the district court and the Fifth Circuit misapplied Rules 56(d) and 37, disregarding Rule 26(f) 's requirement for initiating discovery.

2. Whether federal courts may, consistent with the Constitution 's Supremacy Clause and Contract Clause, impose sanctions against a litigant solely for asserting a claim of title under a federal land patent —contrary to this Court 's precedents recognizing land patents as the highest evidence of title.

Whether a district court may grant summary judgment without affording any opportunity for discovery contrary to Celotex Corp. v. Catrett, where the district court and the Fifth Circuit misapplied Rules 56(d) and 37