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Naamjp Files Petition for Certiorari Asking the U.S. Supreme Court To No. _________ ================================================================ In The Supreme Court of the United States --------------------------------- --------------------------------- NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF MULTIJURISDICTION PRACTICE, (NAAMJP), et al., Petitioners, v. BERYL A. HOWELL, CHIEF JUDGE, U.S. DISTRICT COURT FOR THE DISTRICT OF COLUMBIA, et al., Respondents. --------------------------------- --------------------------------- On Petition For Writ Of Certiorari To The United States Court Of Appeals For The District Of Columbia Circuit --------------------------------- --------------------------------- PETITION FOR WRIT OF CERTIORARI --------------------------------- --------------------------------- JOSEPH ROBERT GIANNINI Counsel of Record NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF MULTIJURISDICTIONAL PRACTICE 12016 Wilshire Blvd. #5 Los Angeles, CA 90025 [email protected] (310) 442-9386 ================================================================ COCKLE LEGAL BRIEFS (800) 225-6964 WWW.COCKLELEGALBRIEFS.COM i QUESTIONS PRESENTED In Frazier v. Heebe, 482 U.S. 641 (1987), this Hon- orable Court exercised its supervisory power and abro- gated a Louisiana Federal District Court local rule that disqualified out-of-state attorneys for general bar admission privileges on the basis of office location, holding “the location of a lawyer’s office simply has nothing to do with his or her intellectual ability or ex- perience in litigating cases in Federal District Court.” Id. at 649. The Court of Appeals for the District of Co- lumbia refused to exercise this Honorable Court’s own unique supervisory power on the ground that it did not possess this power and it thus refused to adhere to this Court’s holding in Frazier v. Heebe. The questions presented are: 1. Are Federal District Court local rules that cat- egorically disqualify otherwise competent and licensed out-of-state attorneys in good standing for general bar admission privileges on the basis of office location law- ful? 2. Whether United States District Court local rules – that block the free expression of the Bill of Rights protected freedoms to counsel expressive asso- ciation, and to petition the government for the redress of grievances on the categorical basis of office location – exceed the District Court’s prescribed local rule-mak- ing authority. ii LIST OF PARTIES Petitioners are the National Association for the Advancement of Multijurisdiction Practice (NAAMJP), Marinna L. Callaway, and Patent Lawyer Doe. Jose Je- huda Garcia and Herbert Howard Detrick II, are no longer parties. Respondents are Beryl A. Howell, Chief Judge U.S. District Court for the District of Columbia, and the other District Judges including: Emmet G. Sullivan, Colleen Kollar-Kotelly, Ellen S. Huvelle, Reggie B. Wal- ton, John D. Bates, Richard J. Leon, Rosemary M. Col- lyer, Robert L. Wilkins, James E. Boasberg, Amy Bermnan Jackson, Rudolph Contreras, Ketanji Brown Jackson. These Article III judicial officers are sued in their official capacities. The Attorney General was a party below. Petition- ers are not contesting his dismissal. CORPORATE DISCLOSURE STATEMENT The National Association for the Advancement of Multijurisdiction Practice is a public benefit corpora- tion. It is not a publicly traded company. It has no par- ent, subsidiaries or affiliates. It issues no stock. iii TABLE OF CONTENTS Page QUESTIONS PRESENTED ................................ i LIST OF PARTIES .............................................. ii CORPORATE DISCLOSURE STATEMENT ...... ii PETITION FOR A WRIT OF CERTIORARI ....... 1 OPINIONS BELOW ............................................. 1 JURISDICTION ................................................... 1 CONSTITUTIONAL PROVISIONS AND STAT- UTES INVOLVED ............................................ 2 STATEMENT OF THE CASE.............................. 2 1. The Federal Right to Counsel .................... 17 2. The Federal Right to Petition .................... 18 3. The Substantive Right to Be Free From Federal Speaker Discrimination on Matters of Public Concern and Prior Restraint ........ 20 4. The Substantive Right to Be Free From Federal Content Discrimination ................ 22 5. The Substantive Right to Be Free From Federal Viewpoint Discrimination ............ 23 6. Equal Protection/ Standard of Review ...... 24 REASONS FOR GRANTING CERTIORARI ....... 27 I. THIS COURT HAS A NON-DELEGABLE DUTY TO GRANT REVIEW AND EXER- CISE ITS SUPERVISORY RESPONSI- BILITY OVER THE QUESTIONS PRESENTED ............................................. 27 iv TABLE OF CONTENTS – Continued Page II. SUPERVISORY REVIEW IS NECESSARY AND PROPER BECAUSE DISTRICT COURT LOCAL RULE DISCRIMINATION ON THE CATEGORICAL BASIS OF OF- FICE LOCATION EXCEEDS PRESCRIBED LOCAL RULE-MAKING STANDARDS ..... 32 III. THIS COURT’S OWN UNIQUE SUPER- VISORY REVIEW IS THE ONLY REAL OPPORTUNITY FOR MEANINGFUL JU- DICIAL REVIEW OF THE HODGE- PODGE OF FEDERAL LICENSING STANDARDS ............................................. 37 CONCLUSION ..................................................... 38 APPENDIX Opinion, United States Court of Appeals for the District of Columbia Circuit (March 14, 2017) ...... 1a Memorandum & Order, United States District Court, District of Columbia (December 31, 2015) ...................................................................... 14a Order Denying Panel Rehearing, United States Court of Appeals for the District of Columbia Circuit (May 18, 2017) .......................................... 50a Order Denying Rehearing En Banc, United States Court of Appeals for the District of Co- lumbia Circuit (May 18, 2017) .............................. 52a v TABLE OF CONTENTS – Continued Page Constitutional Provisions, Statutes, and Rules Involved U.S. Const. amend. I .............................................. 54a U.S. Const. amend. VI ........................................... 54a 28 U.S.C. § 332 ....................................................... 54a 28 U.S.C. § 2071 ..................................................... 54a 28 U.S.C. § 2072 ..................................................... 54a Federal Rule of Civil Procedure 83 ....................... 55a Federal Rule of Appellate Procedure 46 ............... 57a vi TABLE OF AUTHORITIES Page CASES Barnard v. Thorstenn, 489 U.S. 546 (1989) ............ 3, 16 BE&K Constr. Co. v. NLRB, 536 U.S. 516 (2002) ....... 19 Bill Johnson’s Restaurants, Inc. v. NLRB, 461 U.S. 731 (1983) ........................................................ 19 Citizens United v. Federal Election Commission, ___ U.S. ___, 130 S. Ct. 876 (2010) .................... 20, 21 Frazier v. Heebe, 482 U.S. 641 (1987) ................. passim Holder v. Humanitarian Law Project, 561 U.S. 1, 130 S. Ct. 2705 (2010) ................................. 24, 25, 26 Lowe v. SEC, 472 U.S. 181 (1985) ............................... 25 Luis v. U.S., 136 S. Ct. 1083 (2016) ............................ 18 Matal v. Tam, __ U.S. __ (2017) .................................. 23 NAACP v. Button, 371 U.S. 415 (1963) ................. 17, 18 R.A.V. v. Minnesota, 505 U.S. 377 (1992) ................... 23 Reed v. Town of Gilbert, 135 S. Ct. 2218 (2015) ......... 22 Schware v. Bd. of Bar Examiners, 353 U.S. 232 (1957) ................................................................. 25, 26 Sperry v. Florida, 373 U.S. 379 (1963) ........... 13, 14, 16 Supreme Court of New Hampshire v. Piper, 470 U.S. 274 (1985) .......................................................... 2 Supreme Court of Virginia v. Friedman, 487 U.S. 59 (1988) .................................................................... 2 vii TABLE OF AUTHORITIES – Continued Page CONSTITUTIONAL PROVISIONS U.S. Const. amend. I ........................................... passim U.S. Const. amend. VI ..................................... 17, 18, 19 U.S. Const. art. III ..................................... 14, 28, 32, 37 STATUTES 5 U.S.C. § 500(b) ...................................................... 4, 35 28 U.S.C. § 332 (West U.S.C.A. 2006) ......................... 33 28 U.S.C. § 332(d)(4) ................................................... 33 28 U.S.C. § 1254(1) ........................................................ 1 28 U.S.C. § 1654 .......................................................... 17 Rules Enabling Act 28 U.S.C. § 2071 ............................................... passim 28 U.S.C. § 2072 ............................................... passim 28 U.S.C. § 2072(b) .................................................. 36 RULES AND REGULATIONS Amended Local Criminal Rule 57.21 ........................... 7 Amended Local Civil Rule 83.8 .................................... 7 Fed. R. Civ. Proc. 1 .................................................... 4, 6 Fed. R. Civ. Proc. 12(b)(6) .............................. 1, 9, 10, 14 Fed. R. Civ. Proc. 81 ...................................................... 5 Fed. R. Civ. Proc. 83 .............................. 4, 17, 33, 35, 36 viii TABLE OF AUTHORITIES – Continued Page Fed. R. App. P. 46 ................................................ 4, 5, 35 Fed. R. App. P. 47 ........................................................ 33 Supreme Court Rule 5 ........................................ 4, 5, 35 OTHER AUTHORITIES ABA Commission on Ethics 20/20 (2012) .................. 10 David D. Siegel, Commentary on 1988 Revision ........ 32 Declaration from Dr. Mark Leary, the Garonzik Professor of Psychology and Neuroscience and the Director of the Social
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