Petition for Rehearing — Joyce Ann Smith, Petitioner v. City of Princeton, Texas, et al.

No. 18-7791

IN THE SUPREME COURT OF THE UNITED STATES

JOYCE ANN SMITH, pro-se Petitioner.

VSCITY OF PRINCETON, TEXAS, Respondents,

FIRST CHOICE TOWING, Respondents.

JOYCE ANN SMITH, PRO-SE MOTION FOR REHEARING

THE UNDERSIGNED party moves the Court for an order rehearing a prior of the

Court. The Court entered an order on April 15, 2019. I am asking the Court for a

rehearing on the motion because of Constitutional and Statutory Provisions

Involved:

42. U.S.C. 1983 Municipal Liability (Monroe v. Pape, 365 U.S. 167(1961).

18 U.S.C. Section 242 Deprivation of Rights under the color of Law (United

States v. Price, 383 U.S.787 (1966).

18 U.S.C. 1956(a) (1) Laundering of Monetary Instruments (United States v.

Emerson, 128F 3d 557, 561 (7th Cir. 1997)

Texas Penal- Code Section 31.03(a) (c) (6) Unlawful Appropriation without

the owner's consent.

A 12(B) (6). MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM IS RARELY

GRANTED. Myers v. Guardian Life Ins. Co. of Am., SF. Supp 2d 423(D.Miss.1998),

citing Clark v. Amoco Pro.Co., 794 F.2d 967, 970(5th Cir. 1986); Sosa v. Coleman,

646 F.2d 991,993(5th Cir.1981).

The Court must construe the complaint in favor of the Petitioner and assume the

truth of the facts pleaded. Brown v. NationsBank Corp., 188F_3d 579, 586 (5th cir

1999). The complaint should not be dismissed unless "it is clear that no relief

could be granted under any set facts that could be proved consistent with the

allegations." Hishon v. King & Spalding, 467 U.S. 69, 73(1984). In a civil rights

action, the court should not frustrate the broad remedial purpose of the statute

by narrowly applying the exceptions though the limitations period. Briley v. State

of Cal., 564 F2d 849,855(CA Cal. 19777..

TRECEIVED I

MAY -72019

OFFICE OF THE CLERK I

SUPREME COURT,

It is upon the Petitioner as the party that carries the burden of proof on this issue,

to identify to the Supreme Court specific, competent evidence that resolves an

undisputed issue of facts and articulate how that evidence weighs in Petitioner

Favor.

Other than the raw facts submitted, Petitioner have provided the court with

statistical information and cited specific City of Princeton Texas (Ord. No. 201508-17, § 3, 8-17-2015) for HOA's that all support Petitioner position.

The Supreme Court must CULL through this governing ordinances, Petitioners

Exhibits to determine whether Petitioner conclusory representation is accurate.

To that end, Petitioner have also proved to verify the authenticity of the

Governing Ordinances, (Ord. No. 2015-08-17, § 3, 8-17-2015). Petitioner also

submitted exhibits of evidence to support all claims.

I certify that a copy of this motion was mail

o the persons listed below n April

27, 2019.

E ANN SMITH pro-se Petitioner

1123 Augustin Drive

Princeton, Texas 75407

Phone No. 972.704.9365

Respondents:

Paul Pearce P.O. Box 279 Weston, Texas 75097

Anne Angell 5610 North McDonald Street McKinney, Texas 75454

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