No. __________ In The Supreme Court of the United States ♦ DEBRA K. SANDS, Petitioner, v. JOHN R. MENARD, JR., MENARD THOROUGHBREDS, INC., MENARD, INC., WEBSTER HART AS TRUSTEE OF THE JOHN R. MENARD, JR. 2002 TRUST AND RELATED TRUSTS, ANGELA L. BOWE AS TRUSTEE OF THE JOHN R. MENARD, JR. 2002 TRUST AND RELATED TRUSTS AND ALPHONS PITTERLE AS TRUSTEE OF THE JOHN R. MENARD, JR. 2002 TRUST AND RELATED TRUSTS, Respondents. ♦ On Petition for Writ of Certiorari To The Wisconsin Supreme Court ♦ PETITION FOR WRIT OF CERTIORARI ♦ Mel C. Orchard, III Daniel R. Shulman THE SPENCE LAW FIRM, LLC Counsel of Record 15 South Jackson Street Richard C. Landon Post Office Box 548 GRAY, PLANT, MOOTY, Jackson, WY 83001 MOOTY & BENNETT, P.A. Telephone: (307) 733-7290 500 IDS Center 80 South Eighth Street Minneapolis, MN 55402 Telephone: 612-632-3000
[email protected] Counsel for Petitioner i QUESTIONS PRESENTED The Fourteenth Amendment prohibits a State from depriving any person of property without due process of law. For more than nine years, the Petitioner in this case, Debra K. Sands, litigated a claim for un- just enrichment against her fiancé, John R. Menard, Jr., reported to be the richest man in Wisconsin and a major contributor to organizations supporting the candidacy of multiple Wisconsin Supreme Court Justices. During those nine years, which never re- sulted in a trial, the sole issue contested by the parties was whether Sands’ claim was barred by a Wisconsin Supreme Court Rule of Professional Responsibility. On December 29, 2017, the Wisconsin Supreme Court, finding for Sands on the ethical issue, nevertheless ruled that Sands’ complaint failed to state a claim for unjust enrichment, an issue never raised, briefed, or previously argued.