Arbitration ERISA DueProcess
1. Judicial Abdication and Due Process
Whetherthe Eleventh Circuit 's 100-day (and ongoing) failure to rule on an
emergency mandamus petition —where the Petitioner has documented a federal
agency operating without legal authority and a resulting life-threatening medical
and economic crisis —constitutes a denial of due process and access to justice
under the Fifth Amendment.
2. Ultra Vires Agency Action and Fraud on the Court
Whether a writ of mandamus should issue to vacate orders of a district court that
relied on the enforcement actions of a federal agency (the NLRB) that was acting
without a lawful quorum, rendering its litigation efforts ultra vires and its
representations to the district court a fraud upon the judiciary.
3. Structural Constitutional Remedy
Whether this Court should exercise its supervisory power to dismiss all underlying
enforcementactions initiated by the NLRB during its period of unconstitutional
operations to remedy a systemic breakdown in the rule of law and prevent further
irreparable harm to Petitioner.
Whether the Eleventh Circuit's 100-day failure to rule on an emergency mandamus petition constitutes a denial of due process and access to justice under the Fifth Amendment