United States Supreme Court Petition for Writ of Certiorari

Forma En Pauperis Petition Submitted to the Clerk of the United States Supreme Court

The petition was denied as untimely. However, examination of the forma en pauperis instructions as well as laws referred to in the instructions are inconsistent with the actual form provided creating confusion leading to error. Basically an intentional trick showing collusive, evasive behavior by the second highest court in the land and the highest court intended to deprive the public or right to redress by continual assignment to prejudiced judges.

When the unrecorded rule changes or making of rules of the district court controlling the assignment of judges occurred by abrogation of rules designed in the past to be to be surgically sabotaged by stripping of carefully placed statements. The subsequent loss of rights by inability to recognize this matter in the ninth circuit is easily defined as collusion by the ninth circuit and then later the supreme court all serving to create a methods to provide rules to the district courts that appear to satisfy their lawfulness, when the rules themselves are not made under laws of the constitution.

FILED, CONFORMED face page of petitioner Kathleen Ousey

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No.___________________

___________________________

IN THE

SUPREME COURT OF THE UNITED STATES

_________________________

CHRISTOPHER A. BROWN,- PETITIONER

VS.

SANTA BARBARA COUNTY ET. AL,-RESPONDENT

ON PETITION FOR A WRIT OF CERTIORARI TO

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

PETITION FOR WRIT OF CERTIORARI

CHRISTOPHER A. BROWN

POB 61925

SANTA BARBARA CA 93160

i

QUESTION(S) PRESENTED

Whether these petitioners; by petitioning this court, receive Federal, constitutional, protection of rights when district court rules drastically effecting the assignments of magistrates and judges are made without public notice, without record of the change, without opportunity for commentary upon these rules as they control US courts, stand, when they are not made pursuant to the statutes controlling making of rules and they are not consistent with acts of congress or serving the purposes and duties of the Administrative Office of the United States Courts federal Judiciary to conserve or enhance society's trust in the federal courts?

Whether these petitioners will be able to plead these allegations and claims and obtain justice in a district court if defendants are allowed to change the allegations and claims against them in order to create defenses when the changed allegations and claims are accepted by the district court appearing as a defacto "denial-of-access-to-the-courts" enabled with "rule making" controlling the assignment of magistrates and judges of district courts in ways inconsistent with acts of congress?

Whether these petitioners seeking lawful and rightful injunctive relief in protection of Constitutional rights as protection from retaliation of a municipality against them for the attempted use of those rights to gain lawful performance of state laws in petitioners efforts to obtain medical treatment for himself, family, friends and community as well as the general public by a court order from the district court for injunctive relief and compelling specific performance of the defendant municipality pursuant to state laws medically benefiting the public when state courts are too prejudice or acting on conflicts of interests to do so Constitutionally.

ii

LIST OF PARTIES

[ ] All parties appear in the caption of the cases on the cover page.

[ X ] All parties do not appear in the caption of the case on the cover page. A list of all parties to the proceeding in the court whose judgment is the subject of this petition is as follows:

Plaintiff CHRISTOPHER A. BROWN is an unmarried man and at all times pertinent to this complaint was a resident of the County of Santa Barbara

Plaintiff KATHLEEN OUSEY is an unmarried woman and at all times pertinent to this complaint was a resident of the County of Santa Barbara

Plaintiff LINDA RUIZ is an unmarried woman and at all times pertinent to this complaint was a resident of the County of Santa Barbara

Defendant COUNTY OF SANTA BARBARA is a duly constituted governmental entity in the state of California.

As a COUNTY supervisor and Defendants supervisor, Defendant SUSAN ROSE is a board member responsible for appointment, supervision, discipline and dismissal.

COUNTY Counsel SHANE STARK is an employee of the COUNTY has a responsibility to provide counsel to the COUNTY supervisors and other departments and a duty to the public to oversee the legal affairs of the COUNTY in accord with public safety and interest.

District Attorney, THOMAS SNEDDON is an employee of the Defendant and responsible for the hiring, training, retention, supervision, discipline, retraining and dismissal of the District Attorneys Office.

KELLY MCLAUCHLIN is an employee of the Defendant and responsible for constitutional conduct as an attorney for the Defendant COUNTY.

iii

LIST OF PARTIES

Commissioner COLLEEN STERNE, is an employee of the State and responsible as a magistrate or officer of the court to observe the US Constitution.

Public Defender JAMES EGAR, is an employee of the Defendant and responsible for the hiring, training, retention, supervision, discipline, retraining and dismissal of the Public Defenders Office.

Deputy Public Defender RAI MONTES DE OCA, is an employee of the Defendant and responsible for constitutional conduct as an attorney for the Defendant COUNTY in the publics behalf.

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TABLE OF CONTENTS

OPINIONS BELOW 1

JURISDICTION 2

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED 3

STATEMENT OF THE CASE 7

REASONS FOR GRANTING THE WRIT 14

CONCLUSION 16

INDEX TO APPENDICES

APPENDIX A 17

Memorandum of the United States Court of Appeals

for the Ninth Circuit, filed October 5, 2007.

APPENDIX B 20

Order of the United State District Court central District

of California-Western Division, filed July 21, 2006

APPENDIX C 22

Report and Recommendations of United States

Magistrate Judge, filed June 29 2006

APPENDIX D 37

Judgment of the United States Court of Appeals for the

Ninth Circuit, filed January 16, 2008

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TABLE OF AUTHORITIES CITED

CASES PAGE NUMBER

Morales v. City of Los Angeles (9th Cir. June 12, 2000) 214 F.3d 1151 9, 10, 11

Karim-Panahi, 839 F.2d at 625 10, 11, 12

Hal Roach Studios. Inc. v. Richard Feiner and Co. Inc., 896 F.2d 1542, 13

1555 n.19 (9th Cir. 1990)

Conley v. Gibson (1957) 355 US 41, 45-46 12

STATUTES AND RULES

28 CFR t 35, App A§35.104;pt36,A pp B §36104 3, 8

28 CFR §35.130 3, 8

28 CFR § 35.134 8

28 CFR § 35.178 8, 9

42 USC §12131 3, 8

42 USC §12203 3

42, U.S.C. §§ 1983, 18 U.S.C. 4, 6

18 U.S.C. § 241 4, 6

28 U.S.C. 1343(a)(3) 4, 6

28 U.S.C. §§ 1331 4, 6

28 U.S.C. § 1367(a) 4, 6

California Health and Safety Code (CHS) 1370.4 3, 4, 7, 11

vi

IN THE

SUPREME COURT OF THE UNITED STATES

PETITION FOR A WRIT OF CERTIORI

Petitioner respectfully prays that a writ of certiorari issue to review the judgement below.

OPINIONS BELOW

[ X ] For cases from federal courts:

The opinion of the United States court of appeals appears at Appendix___A___ to

the petition and is

[ ] reported at __________________________________ ; or,

[ ] has been designated for publication but is not yet reported; or

[ X ] is unpublished.

The opinion of the United States district court appears at Appendix ___B____ to

the petition and is

[ ] reported at ____________________________________ ; or,

[ ] has been designated for publication but is not yet reported; or

[ X ] is unpublished.

[ ] For cases from state courts:

The opinion of the United States court of appeals appears at Appendix___ ___ to

the petition and is

[ ] reported at __________________________________ ; or,

[ ] has been designated for publication but is not yet reported; or

[ ] is unpublished.

The opinion of the United States district court appears at Appendix ___ ____ to the petition and is

[ ] reported at __________________________________ ; or,

[ ] has been designated for publication but is not yet reported; or

[ ] is unpublished.

1.

JURISDICTION

[ X ] For cases from federal courts:

The date on which the United States court of appeals decided my case

was __October 5, 2007____

[ ] No petition for rehearing was timely filed in my case.

[ X ] A timelypetition for rehearing was denied by the United States Court of Appeals on the following date: __January 16, 2008__ , and a copy of the order denying rehearing appears at Appendix ___D____ .

[ ] An extension of time to file the petition for writ of certiorari was granted to and including _____________________ (date) on _____________________ (date) in Application No. ___ A_____.

The jurisdiction of this court is invoked under 28 U.S.C. § 1254(1).

[ ] For cases from state courts:

The date on which the highest state court decided my case was _______________

A copy of that decision appears at Appendix ________ .

[ ] A timely petition for rehearing was hereinafter denied on the following date: ______________ , and a copy of the order denying rehearing

appears at Appendix _________ .

[ ] An extension of time to file the petition for writ of certiorari was granted to and including _____________________ (date) on _____________________ (date) in Application No. __________.

The jurisdiction of this court is invoked under 28 U.S.C. § 1257(a).

2.

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

Petitioner alleged in district court that state courts are acting unconstitutionally through deprivation of equal protection of law and due process violations, as a practice or policy for the purpose of protecting County interests and evasion of compliance with state laws since 1998. It is alleged in the complaint of the district court that these deprivations f Constitutional rights are motivated by retaliation for petitioners attempts to gain conformance to state law by the County to state laws in State courts as he sought medical treatment for his disability, a violation of 42 USC §12203. Substantially, state courts are shown to be used as tools for persecuting a citizen who simply demands, because of great medical need, that the municipality follow laws pertaining to the acquisition, development and public availability of appropriate medical treatments by cooperation with the public pursuant to CHS 1370.4.

Petitioner satisfies the requirements of "QUALIFIED INDIVIDUALS WITH DISABILITIES" 28 CFR t 35, App A§35.104;pt36,A pp B §36104, being diagnosed with Attention Deficit Hyperactivity Disorder (ADHD), by a licensed clinical psychologist justifying REASONABLE MODIFICATIONS 28 CFR §35.130 by a PUBLIC ENTITY, 42 USC §12131, courts are considered public entities. Plaintiffs requests REASONABLE MODIFICATIONS and observance of F.R.Civ.P. 61. Harmless Error, by balancing the deprived rights of plaintiffs, against minor deficiencies, errors and omissions of this petition for writ of certiorari.

The district court rules prior to the abrogation of rules granted plaintiff/petitioners a reassignment of magistrate and judge when petitioner refiled in the district court with new co-plaintiffs, Kathleen Ousey and Linda Ruiz. The default rules made by abrogation in July of 2005 omit aspects "consistent with acts of Congress" or reassignment upon the established expansion of the violations of civil rights and non/mis/malfeasance to other citizens, by defendant municipality,

3.

is substantiated by the additional plaintiffs seeking redress by request for injunctive relief for violations of; 42, U.S.C. §§ 1983, 18 U.S.C., PART I, CHAPTER 13 Sec. 241, 28 U.S.C. 1343(a), 28 U.S.C. §§ 1331, 28 U.S.C. § 1367(a) in this case. Relief protecting the rights of petitioner which also assures the defendant municipality will act pursuant to specific performance demands developing the medical treatment pursuant to law; California state Health and Safety Code 1370.4; in a realistic manner benefiting all citizens of that county and potentially the entire nation eventually.

A question in the case of this petition before the court relates to; 28 U.S.C. §§ 2071 (a) reads that "all courts" are empowered to "prescribe rules for conduct of their business", "but such rules shall be consistent with acts of Congress and rules of practice under section 2072 pursuant to this title."

When a rule is abrogated by the judicial council of the relevant circuit, it (Ninth Amendment) "shall not be construed to deny or disparage others retained by the people." Petitioner retains his right to equal protection of law. The abrogation of the lower courts rules did not leave rules (§§ 2071 (a) "consistent with Acts of Congress and rules of practice and procedure prescribed under section 2072"

28 U.S.C. §§ 2071 e) If the prescribing court determines that there is an immediate need for a rule, such court may proceed under this section without public notice and opportunity for comment, but such court shall promptly thereafter afford such notice and opportunity for comment.

4.

No public notice was provided to the change of rules effecting rights which does "deny or disparage others retained by the people.", the petitioner.

28 U.S.C. §§ 2071 (c)(2) Any other rule prescribed by a court other than the Supreme Court under subsection (a) shall remain in effect unless modified or abrogated by the Judicial Conference.

The judicial conference has not abrogated the rules or rule which were prescribed under 28 U.S.C. §§ 2071 (a) and making of rules by abrogation of the judicial council with such wide reaching impact that such rules would necessarily be made not by judicial council but by judicial conference or the Supreme Court to be consistent with related acts of congress. The enumeration in the Constitution, of the right to equal protection of law, shall not be construed to deny or disparage the right retained by the people to see that 28 U.S.C. §§ 2071 (a) is held over elements of (c) which create inconsistency with acts of congress and Article III United States where the "The judicial power shall extend to all cases, in law and equity, arising under this Constitution, the laws of the United States". Accordingly, since the petition for rehearing never considered these factors of the making of rules by abrogation not consistent with acts of congress, this petition for writ of certiorari defines conditions where petitioners case should be heard by the district court under rules originally made by judicial conference or the supreme court or that rules made under 28 U.S.C. §§ 2071 (a) should remain in effect

28 U.S.C. §§ 2071 (f) No rule may be prescribed by a district court other than under this section.

5.

The judicial council has effectively prescribed rules in a manner that is making or implying an unfair distinction by default in the petitioners case, as the assigned magistrate and judge allow defendant municipality to effectively change plaintiffs allegations, claim and demand, relating to municipal conformance to state laws and civil rights, thusly applying a more unfair distinction to petitioner of accepting fraudulent defenses than the alternative of, "inadequate defenses". The rules have been shown to be inconsistent with acts of congress and do not protect petitioners and rights of the public pursuant to 28 U.S.C. §§ 2071 (a), Operation under rules in effect prior to July 2005 keep the court operating in absolute public interest, greatly so with the improved medical treatment; otherwise the district court effects defacto "denial-of-access-to-the-courts" for redress of petitioners claims that show violations of statutes, 42, U.S.C. §§ 1983, 18 U.S.C., PART I, CHAPTER 13 Sec. 241, 28 U.S.C. 1343(a), 28 U.S.C. §§ 1331, 28 U.S.C. § 1367(a) or civil rights violations of deprivation of equal protect and due process extending back a decade as pattern, practice and policy designed to enable evasion of compliance to state laws. Such statutes as 28 U.S.C. §§ 2071 (a) exist to protect petitioners constitutional rights. It appears that the rule change which resulted in significant evidence of gaucheries caused a circumvention, denial and obstruction of justice in direct violation of due process of the petitioner's rights. By this rule change, these subsequent gaucheries, the court has overstepped it's authority without full accountability, which existed prior to the rule being abrogated. Further, this rule change appears to manifest from a "roundtable" at the judicial conference, without a formal hearing, without formal specific notice, and without formal testimony, further depriving the Petitioner and public an opportunity to prevent the rule change from occurring. Petitioner claims and invokes those rights on his behalf and the behalf of co plaintiff/petitioners in petition for review and writ of certiorari for this case.

6.

STATEMENT OF THE CASE

Petitioner subpoenaed the custodian of records of the County to trial with records that are made available to the public by law for inspection from a suit in State court decided in 1998 alleging infliction of mental and emotional distress whereupon the municipality failed to appear depriving the petitioner of information needed for medical diagnosis and treatment. Efforts to gain the municipalities conformance to state law, CHS 1370.4 as a well as medical information for diagnosis and treatment, include use of a FOIA request that was subsequently ignored and record of its service removed from the clerk of the boards record. Since that time mental impairment that substantially limits one or more of petitioners major life activities has increased far beyond the suffering that drove the petitioner to take legal action. Petitioner has a record of such an impairment and that impairment substantially limits a major life activity and is regarded as having such an impairment and is a qualified disabled individual under the Americans with Disabilities Act of 1990 which has been invoked in the filing of the district court.

Prior to formal Attention Deficit Disorder (ADHD hereinafter) diagnosis petitioner was subjected to the following deprival’s of equal protection of law and due process, as he sought information from records of the municipality for medical and mental diagnosis and treatment. Each deprival of due process and rights by state courts is proven with evidence of the complaint.

A. Issuance of erroneous and deficient minute orders depriving petitioner of appeal, first when issued by the court, then again when formal amendment was sought.

B. Testimony from the audience at trial not under oath by judicial officers without notation in the record of their testifying status as witnesses

C. Judicial refusal to call non-objecting defendant to stand for testimony at trial.

D. Continuance of hearing without notice.

7.

E. Citation and imposition of local court rules not published

F. Failure to recognize non-appearance of defendant in small claims court as standard justification for default judgment provided to every other citizen.

G. Refusal and failure to examine evidence against defendant in small claims court

After petitioner was diagnosed with ADHD the deprival’s continued as violations of American with Disabilities Act statutes

28 CFR t 35, App A§35.104;pt36,A pp B §36104

28 CFR §35.130

this was done by a PUBLIC ENTITY as defined in 42 USC §12131 despite notice to the court of the petitioners disabled status. Petitioner opposed the practice of the court to disregard his disabled status and did so by repeated formal notice in the record of his disabilities. Escalated deprival’s after that indicate the state court is conducting retaliation, a violation of 28 CFR §35.134. Pursuant to 28 CFR §35.178 "A State shall not be immune under the eleventh amendment to the Constitution of the United States from an action in Federal court of competent jurisdiction for remedies of law or equity".

H. Refusal to recognize written, confirmed perjury on state court judicial council forms

I. Alteration of transcripts of family law court containing judicial admissions of failure to examine evidence in small claims court.

J.. Refusal to make reasonable accommodations due to physical disability established by physicians examination and written diagnosis or recognize disability.

K. Refusal to make reasonable accommodations due to acknowledged psychological disability established written diagnosis of licensed psychologist or recognize disability.

8.

L. The order from a Marsden motion denied represents the proceeding falsely then requested amendment is denied.

M. Refusal to provide judge for hearing instead of commissioner on written objection.

The below are deprivations of rights and due process after the timely filed appeal in the United States Court of Appeals for the Ninth Circuit September 25, 2006.

N. Motion to Quash based on estopple filed June 22, 2006 never assigned and heard.

O. Declaration of court commissioner compared to the record is shown to have false information regarding the Motion to Quash.

P Clerks refuse to file petitioners motion to strike declaration and will only accept the pleading by stamp of "received".

Q Court assigned to decide disqualification of commissioner does not render decision on petitioners motion to strike which is stamped "received", instead of "filed" by clerk and court denies disqualification leaving false information in the record and prejudiced commissioner, a defendant in this case, violating petitioners rights and rendering decisions.

Excepting that the petitioners case involves state courts and their conflict of interests historically based, the petitioners case is very similar to Morales v. City of Los Angeles supra in allegations which shows liability after trial courts conclude adversely; a fact in petitioners favor seeking certiorari in support of injunctive relief as it is pursuant to 28 CFR §35.178 protecting civil rights and specific performance with wide public benefit after adverse conclusion in district courts and appellate courts but never heard at trial eliminating res ajudicata. Injunctive relief ends the

9.

ongoing discrimination to a citizen due to his efforts to gain action from a municipality obligated by law to enable the public to gain the medical cooperation of their health department benefiting from a state health plan for development of investigative and experimental medical treatments pursuant to CHS 1370.4.

The petitioners case differs again from Morales supra as it is not a tort or money claim but has been concluded adversely after being manipulated by defendants defense to appear as a tort claim, accepted only because of the making of local court rules not consistent with acts of congress and not made according to statutes .

The filed complaint of the district court is similar in structure to Morales supra showing liability, however plaintiff's in this case sought accountability by asking the district court to compel lawful and Constitutional performance by state courts in the form of injunctive relief for protection of federal civil rights in the state court and specific performance to gain municipal conformance to state laws when state courts are prejudice or subject to conflicts of interests.

Morales v. City of Los Angeles (9th Cir. June 12, 2000) 214 F.3d 1151. [2].............. We also note that our decisions in Delew v. Wagner, 143 F.3d 1219 (9th Cir.), cert. denied, 525 U.S. 1015 (1998), and Karim-Panahi v. Los Angeles Police Dep't., 839 F.2d 621 (9th Cir. 1988), are not at all inconsistent with our conclusion today. In both Delew and Karim-Panahi , the plaintiffs brought denial-of-access-to-the-courts claims arising from alleged police misconduct occurring in on-going state trial court proceedings. We held that such claims are not ripe until the trial court proceedings are concluded adversely to the plaintiffs. Delew, 143 F.3d at 1223; Karim-Panahi, 839 F.2d at 625.

10.

A denial-of-access-to-courts-claim resulting from claims of official misconduct are recognized in Morales supra ; petitioner has not filed a money claim and only seeks injunctive relief to protect civil rights from official misconduct then seeks specific performance to compel a municipality in the state to act pursuant to state law CHS 1370.4.

A Federal question arises because state courts are prejudiced against petitioner and will not allow petitioner federal, Constitutional rights or fair, Constitutional hearings as petitioner seeks the municipal defendants compliance with state laws providing vital medical treatments for the citizens of the state. Indeed petitioner is discriminated against and persecuted unjustly, egregiously in retaliation for efforts to gain appropriate medical care through legal action in State courts by deprivation of civil rights in the same courts. Co plaintiff Linda Ruiz's daughter died needing the specific performance sought in the term of the appeal. Other family members are endangered, wherein, .... below shows justice defined in the words, "[the] reversal of the adverse judgment would moot such a claim."

[4] We agree that California's tolling rule applies in these cases. It is not inconsistent with federal law. It also has the advantage of promoting judicial economy in that it encourages plaintiffs to wait for the appellate proceedings in the underlying case to fully run their course before initiating a denial-of-access-to-the-courts lawsuit. As previously noted, the reversal of the adverse judgment would moot such a claim. Delew, 143 F.3d at 122-23; Karim-Panahi, 839 F.2d at 625.

11.

The Offices and departments of a public entity can be sued as seen in Karim-Panahi v. Los Angeles supra below. However, in the petitioners case the defendant county has been shown to violate state subpoena law to evade accountability to laws of record keeping related to development of medical treatments having great value to the public and uses the public defender to further those ends.

Karim-Panahi v. Los Angeles Police Dep't, 839 F.2d 621, 624 n.2 (9th Cir. 1988) ("Municipal police departments are `public entities' under California law and, hence, can be sued in federal court for alleged civil rights violations."). Thus, under Rule 17(b) a Police Department may be sued in Federal Court. Shaw, at 605.

Karim-supra defines public entities as being open to suits in federal court. Offices of the municipality are public entities. "Personal involvement" "between each defendants" wrongful conduct and the deprivations has been alleged and established and so liability to injunctive relief is established as complaint is not a tort claim.

"A complaint should not be dismissed for

failure to state a claim unless it appears beyond doubt that the plaintiff can prove no set of facts Conley v. Gibson (1957) 355 US 41, 45-46.

Petitioners can and have stated a clear claim in pleadings with integrated evidence proving a dynamic set of facts; the district court seems to not accept the evidence from plaintiffs but only further advances fraudulent defenses from defendants, and this in a court acting under rules

12.

inconsistent with acts of congress. The evasive and mean spirited actions of the defendant created a need for plaintiffs to generate of unnecessary pleadings in opposition when frivolous, inadequate, false or fraudulent defenses are accepted from defendants by the district court who then terms the petitioners pleading as "confusing" because of their quantity.

In considering the motion, the court may not consider any material “beyond the pleadings.” Hal Roach Studios. Inc. v. Richard Feiner and Co. Inc., 896 F.2d 1542, 1555 n.19 (9th Cir. 1990). However, material which is properly submitted as part of the complaint may be considered. Id. Exhibits submitted with the complaint may also be considered. Durning v. The First Boston Corp., 815 F.2d 1265, 1267 (9th Cir. 1987).

Properly submitted material, much of it court documents, having requisite for Judicial notice, has been submitted by petitioners seeking protection and upholding of constitutional rights and laws protecting the lives and health of themselves, family and friends as well as the public generally. When petitioner was joined in filing for injunctive relief and specific performance by co plaintiffs Kathleen Ousey and Linda Ruiz, it was a violation of due process as it used rules not consistent with acts of congress that at one time, prior to abrogation, provided equal protection of law and constitutional justice.

13.

REASONS FOR GRANTING THE WRIT

Public benefit is potentially immense from the medical treatment. To begin, many families across the nation are involved in a struggle that may include damage from substance abuse. Huge costs are incurred by municipalities for; law enforcement, medical, court systems, jails, welfare and other programs etc., that currently exist with no actual way to effect the abuse which is on the rise. The demands made by the suit of petitioner(s) are such that human suffering and costs can be dramatically reduced for municipalities and state governments across the nation by creating effective drug and alcohol recovery.

Fatalities from drunk driving were 16,885 in 2005. This can be cut drastically by proper review and certiorari, because with development of the proposed treatment, the publics perceived ease of stopping drinking will encourage thousands to seek treatment. Recovery is likely to be permanent because the psychological addiction is treated.

Drug addicts can be rehabilitated by replacing patterns that dominated the addict with other patterns known from earlier in life that are positive and free of obsession with drug use. Currently many US cities have near epidemic methamphetamine use and this treatment shows more promise than any currently in use.

Post Traumatic Stress Syndrome in military personnel can be treated more completely perhaps than with any other method as the extreme behavior or trauma of soldiers in battle can leave deep scars that this treatment can reach, relive and remove.

14.

Domestic violence can be treated at the source. Children can be spared from broken homes or patterning may end up manifesting in their own behaviors 30 years later. Children will benefit greatly, generally, from increased stability in homes that before the treatment, had violence, and or substance abuse.

The possibility of treating schizophrenia with the medical treatment proposed to the municipality shows great promise and represents another massive benefit to the public in addressing a problem that psychiatry has not been able to find solutions for.

Many behavioral disorders that lead to indirectly to serious health problems burdening public health systems, can be treated, which can lead to lowered health costs over time across the nation.

The Administrative Office of the United States Courts federal Judiciary will have increased public perceptions as having taken action to conserve or enhance society's trust in the federal courts by upholding the individuals Constitutional rights to the great benefit of the many.

15.

CONCLUSION

Normally differences in the decision of lower courts justify writs of certiorari by the supreme court. In this instance there has been a defacto making of local court rules which are not made consistent with law or very different or inconsistent with acts of congress while also displacing such rules that are completely consistent with congressional acts. By these means, the agreement of lower courts has been made to appear consistent with law by being consistent with each other and unfairly in defendants favor by the improper utilization's of rules inconsistent with acts of congress.

Collectively the violations of statute, rules, laws and deprival of petitioners Constitutional rights as factors shown in the complaint of the district court merit review based on the questions presented in this petition. Those factors, coupled with the massive potential benefits to the citizens of the United States, an assertion substantiated with evidence in the record, justify review of the petitioner(s) appeal and petition for a writ of certiorari should be granted.

Respectfully submitted,

_______________________________

Christopher A. Brown

Date: ___________________________

16.

 

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