Petition for Writ of Certiorari — Irving F. Rounds, Jr., Petitioner v. Department of Justice, et al.

Supreme Court, U.S.

FILED

MAR 1 2 2026

OFFICE OF THE CLERK

No. 25-J153

In The

Supreme Court of tlje Kniteb States

Irving F. Rounds, Jr.,

Petitioner,

v.

U.S. Department of Justice; Richard Ciruolo,

Agent, Department of Justice; John Coughlin,

Agent, Department of Justice,

Respondents.

On Petition for Writ of Certiorari

to the United States Court of Appeals

for the First Circuit

PETITION FOR WRIT OF CERTIORARI

Irving F. Rounds Jr.

Petitioner (Pro Se)

48 N. Sturbridge Road

Apt. B

Charlton, MA 01507

781-504-8974

roundsmechanical5@protonmail.com

Legal PRINTERS LLC • Washington, DC • 202-747-2400 • legalprinters.com

QUESTIONS PRESENTED

Whether Petitioner was denied due process under the

Fifth Amendment where the lower federal courts:

I.

Dismissed

Petitioner's

sworn claims of

governmental retaliation and threats without

affording any evidentiary hearing or opportunity to

present witnesses, despite factual allegations that

could not lawfully be resolved on the written record

alone;

IL Denied motions for recusal and reassignment

without stating any basis, despite documented

institutional connections between the presiding judges

and the named federal defendants, creating an

appearance of bias too high to be constitutionally

tolerable under Caperton v. A.T. Massey Coal Co., 556

U.S. 868 (2009); and

III. Affirmed dismissal by summary order and denied

rehearing without providing any legal reasoning,

leaving Petitioner unable to determine whether his

constitutional claims were rejected on jurisdictional,

procedural, or merits grounds, in violation of the due

process principles reaffirmed in Noem v. Abrego

Garcia, No. 24A949 (2025).

PARTIES TO THE PROCEEDING

Petitioner (Plaintiff-Appellant below):

Irving F. Rounds, Jr.

Respondents (Defendants-Appellees below):

United States Department of Justice Richard Ciruolo,

Agent, United States Department of Justice John

Coughlin, Agent, United States Department of Justice

RELATED CASES

Irving F. Rounds, Jr. v. United States Department of

Justice et al., No. 4:21-CV-40117-TSH, United States

District Court for the District of Massachusetts,

Worcester Division. Judgment entered September 8,

2022.

Irving F. Rounds, Jr. v. United States Department of

Justice et al., No. 23- 1789, United States Court of

Appeals for the First Circuit. Judgment entered

October 16,2025; rehearing denied December 16,2025.

Irving F. Rounds, Jr. v. Environmental Protection

Agency, No. 1:15-CV- 13541-MLW, United States

District Court for the District of Massachusetts.

Judgment entered August 22, 2016.

Irving F. Rounds, Jr. v. Environmental Protection

Agency et al., No. 4:17- CV-40072-TSH, United States

District Court for the District of Massachusetts,

ii

Worcester Division. Judgment entered February 12,

2018.

Irving F. Rounds, Jr. v. Charles Koch et al., No. 4:18CV-40066-DHH, United States District Court for the

District of Massachusetts, Worcester Division.

Judgment entered June 22, 2018.

Irving F. Rounds, Jr. v. Charles Koch et al., No. 191094, United States Court of Appeals for the First

Circuit. Judgment entered February 27, 2020.

Irving F. Rounds, Jr. v. United States Department of

Justice et al., No. 19-11388-FDS, United States

District Court for the District of Massachusetts.

Judgment entered January 30, 2020.

Irving F. Rounds, Jr. v. Charles Koch et al., No. 20248, Supreme Court of the United States. Certiorari

denied November 2, 2020; petition for rehearing

denied January 11, 2021.

Irving F. Rounds, Jr. v. Commonwealth of

Massachusetts Governor Charlie Baker et al., No.

1984CV03692, Suffolk County Superior Court,

Commonwealth of Massachusetts. Judgment entered

December 9, 2019. Ultimately appealed to the

Supreme Court of the United States in Irving F.

Rounds, Jr., Petitioner v. Maura T. Healey, Governor

of Massachusetts, et al., No. 22-1109, Supreme Court

of the United States.

iii

Irving F. Rounds, Jr., Petitioner v. Maura T. Healey,

Governor of Massachusetts, et al., No. 22-1109,

Supreme Court of the United States. Petition for writ

of certiorari filed May 9, 2023; petition denied June 26,

2023; petition for rehearing filed July 20, 2023;

rehearing denied August 21, 2023. Application

(22A1020) for injunctive relief submitted to Justice

Jackson May 22, 2023; application denied May 24,

2023.

iv

TABLE OF CONTENTS

Page

Questions Presented........................................................ i

Parties to the Proceeding............................................. ii

Related Cases................................................................. ii

Table of Authorities........................................................ vi

Opinions Below...............................................................

1

Jurisdiction .....................................................................

1

Constitutional Provisions Involved...........................

2

Statutes and Rules........................................................

2

Statement of the Case.................................................

3

Reasons for Granting the Writ.................................. 9

Conclusion.............................

16

Appendix................................................................... App. 1

v

TABLE OF AUTHORITIES

Cases

Caperton, v. A. T. Massey Coal Co.,

556 U.S. 868 (2009)

Page

9, 11, 12, 16

Duncan v. Louisiana,

391 U.S. 145 (1968).................................................... 15

Goldberg v. Kelly,

397 U.S. 254 (1970)...................................................

10

Griffin v. Illinois,

351 U.S. 12 (1956)......................................................

12

In re Murchison,

349 U.S. 133 (1955)...................................................

11

Joint Anti-Fascist Refugee Comm'n v. McGrath,

341 U.S. 123 (1951)...................................................

12

Londoner v. City of Denver,

210 U.S. 373 (1908)......................

10

Noem v. Abrego Garcia,

No. 24A949 (2025)...................................................

7, 9

Townsend v. Sain,

372 U.S. 293 (1963)...................................................

10

Wisconsin v. Constantineau,

400 U.S. 433 (1971).................................................... 16

Withrow v. Larkin,

421 U.S. 35 (1975).................................................. 11

Constitutional Provisions, Statutes, and Rules

U.S. Const, amend. V

2, 9, 11, 17

U.S. Const, amend. VII.....................................

2, 15

U.S. Const, amend. XIV...........................................

2

28 U.S.C. § 455(a)...................................................... 2

28 U.S.C. § 1254(1)...............................................

1,2

Fed. R. Civ. P. 60(b)(3)................................... 2, 6, 15

Sup. Ct. R. 10............................................................ 2

Sup. Ct. R. 13............................................................ 2

PETITION FOR A WRIT OF CERTIORARI

Petitioner Irving F. Rounds Jr. respectfully

petitions this Court for a writ of certiorari to review

the judgment of the United States Court of Appeals for

the First Circuit. This Court's jurisdiction is invoked

under 28 U.S.C. § 1254(1), and this petition is

presented pursuant to Rule 10 of the Rules of this

Court.

OPINIONS BELOW

The judgment of the United States Court of

Appeals for the First Circuit in Case No. 23-1789,

entered October 16, 2025, is reproduced at Appendix

A. The order of the Court of Appeals denying petition

for panel rehearing and rehearing en banc, entered

December 16, 2025, is reproduced at Appendix B. The

memorandum of decision and order of the United

States District Court for the District of Massachusetts,

Worcester Division, in Civil Action No. 4:21-cv-40117TSH, entered September 8, 2022, is reproduced at

Appendix C.

JURISDICTION

The judgment of the United States Court of

Appeals for the First Circuit was entered on October

16, 2025. A timely petition for panel rehearing and

rehearing en banc was filed on November 21, 2025,

and denied on December 16,2025. The mandate issued

on December 24, 2025. This petition is timely filed

within 90 days of the December 16, 2025 order denying

1

rehearing, pursuant to Supreme Court Rule 13.1. This

Court's jurisdiction is jnvoked under 28 U.S.C. §

1254(1).

CONSTITUTIONAL PROVISIONS INVOLVED

Fifth Amendment

"No person shall be ... deprived of life, liberty, or

property, without due process of law . . ."

Seventh Amendment

"In Suits at common law . . . the right of trial by

jury shall be preserved . . ."

Fourteenth Amendment

"... nor shall any State deprive any person of life,

liberty, or property, without due process of law . . ."

STATUTES AND RULES

28 U.S.C. § 1254(1)

28 U.S.C. § 455(a)

Fed. R. Civ. P. 60(b)(3)

Sup. Ct. R. 10

Sup. Ct. R. 13

2

STATEMENT OF THE CASE

This case arises from Petitioner's 1998

whistleblower report to the Environmental Protection

Agency's Criminal Investigation Division concerning

violations of the Clean Air Act by his former employer,

Airtron Heating and Air Conditioning, Inc., then

partially owned by Group MAC and the Koch Brothers.

After federal officials abandoned promised witness

protection and shifted to treating Petitioner as a

suspect rather than a protected witness, Petitioner

endured more than two decades of documented

retaliation, threats, and interference with his

employment and reputation. Despite sworn affidavits,

corroborating evidence, and repeated requests for

injunctive relief, no federal court has ever permitted

Petitioner to present witnesses or testimony at an

evidentiary hearing.

A.

Background of the Whistleblower Report

and Subsequent Retaliation

In January 1998, Petitioner was employed by

Airtron Heating and Air Conditioning, Inc., in

Oldsmar, Florida. After witnessing numerous

violations of the Clean Air Act—including illegal

venting of refrigerants and consumer

fraud—Petitioner reported these violations to Special

Agent Daniel Green of the EPA's Criminal

Investigation Division in Tampa, Florida. Agent Green

personally encouraged Petitioner to come forward as a

whistleblower and expressly assured him that he

would receive witness protection and complete

3

immunity.

After Petitioner relied on those assurances and

disclosed substantial information regarding Airtron's

violations, Agent Green reneged on his promise of

protection. Rather than safeguarding a cooperating

whistleblower, federal officials abruptly shifted their

posture following the Department of Justice's highly

publicized scandals during the Whitey Bulger era.

Shortly thereafter, federal agencies began treating

Petitioner not as a protected witness but as a

suspected "environmental terrorist," a false

characterization used to justify surveillance,

intimidation, and threats of arrest.

This abandonment of promised protection was

followed by a coordinated effort between federal agents

and Group MAC'S private security personnel to

fabricate allegations that Petitioner had sabotaged

HVAC systems. These allegations were false and

designed to undermine Petitioner's credibility as a

whistleblower at a time when Group MAC had

recently taken its company public and feared financial

exposure. This pattern of retaliatory conduct by federal

and state actors has persisted for more than two

decades and directly relates to the same network of

individuals and agencies implicated in the present

appeal.

B.

District Court Proceedings and Denial of

Hearings

Petitioner filed the underlying complaint on

4

November 22, 2021, in the United States District

Court for the District of Massachusetts, Worcester

Division, Case No. 4:21-cv-40117-TSH (Hillman, J.),

naming the U.S. Department of Justice and Agents

Richard Ciruolo and John Coughlin as defendants. The

complaint alleged violations of Petitioner's

constitutional rights, including retaliation for

protected whistleblowing activity, threats to personal

safety, and ongoing surveillance and harassment.

Petitioner

submitted sworn affidavits,

documentary evidence, and multiple motions seeking

injunctive relief and requesting an evidentiary

hearing.

At no time did the district court permit Petitioner

to present witnesses, testify under oath, or introduce

evidence through live testimony. Despite Petitioner's

documented allegations—including evidence of a

March 5, 2015 staged automobile crash that nearly

killed Petitioner's former wife, medical records

confirming stress-related health conditions, and

corroborating statements from third parties—the

district court dismissed the complaint on September 8,

2022, without holding any hearing on the factual

record.

Petitioner also moved for recusal and

reassignment, citing institutional connections between

the presiding judge and officials named in related

federal proceedings, as well as the appearance of

structural bias arising from the overlapping

professional relationships between Massachusetts

5

federal judges and Department of Justice leadership.

These motions were denied without explanation.

C.

First Circuit Proceedings and Summary

Affirmance

Petitioner timely appealed to the United States

Court of Appeals for the First Circuit, Case No. 231789. The government moved for summary affirmance.

On October 16, 2025, a panel of the First Circuit

(Barron, C.J., Rikelman and Aframe, JJ.) issued a oneparagraph judgment affirming the district court's

dismissal and denial of Petitioner's Rule 60(b)(3)

motion. The court stated:

Even if we were to assume that plaintiffs

appeal from the order of dismissal was

timely, plaintiff has failed to demonstrate

any error in the court's decision; likewise, we

discern no abuse of discretion in the court's

denial of plaintiff s Rule 60(b)(3) motion. The

government's motion for summary

affirmance is granted and the dismissal of

plaintiffs complaint is affirmed. See 1st Cir.

R. 27.0(c).

The judgment provided no analysis of Petitioner's

constitutional claims, no explanation of the legal

standard applied, and no indication whether the court

reached the merits of Petitioner's due process

arguments or dismissed on other grounds.

6

D.

Petition for Rehearing, Emergency Motion,

and Final Denial

On November 21, 2025, Petitioner filed a

combined petition for panel rehearing and rehearing

en banc, along with an emergency motion for a

temporary restraining order, an affidavit documenting

new evidence of continuing threats and retaliation,

-i- and a motion for leave to exceed the word limit. The

petition invoked this Court's recent decision in Noem

v. Abrego Garcia, No. 24A949 (2025), arguing that the

denial of any evidentiary hearing violated the core due

process principle that individuals cannot be deprived

of liberty based solely on written filings when material

facts are in dispute.

On December 16, 2025, the First Circuit denied

both the petition for panel rehearing and the petition

for rehearing en banc. The order stated: .

The petition for rehearing having been

denied by the panel of judges who decided

the case, and the petition for rehearing en

banc having been submitted to the active

judges of this court and a majority of the

judges not having voted that the case be

heard en banc, it is ordered that the petition

for rehearing and petition for rehearing en

banc be DENIED. Appellant's motion to

exceed the word limit is ALLOWED. All

other pending motions, to the extent not

mooted by the foregoing, are DENIED.

7

Once again, no reasoning was provided. The

mandate issued on December 24, 2025, concluding the

proceedings before the First Circuit.

E.

Pattern of Institutional Protection Across

Multiple Proceedings

The denial of hearings in this case is not an

isolated occurrence. Over the past decade, Petitioner

has sought relief in five separate federal actions across

two district courts in Massachusetts, supported by

more than a dozen motions for injunctions and

emergency hearings. Not one hearing request has been

granted.

These matters have been reviewed by more than

forty federal judges, spanning the district courts, the

First Circuit, and this Court (twice on prior certiorari

petitions). At the state level, Petitioner has likewise

pursued injunctive relief naming the Governor,

Attorney General, and other officials, generating five

hearings reviewed by fourteen state judges.

Throughout these proceedings, every level of the

judiciary has declined to permit Petitioner to present

live testimony, cross-examine witnesses, or introduce

evidence in an adversarial setting. This pattern

mirrors what this Court recently condemned in Noem

v. Abrego Garcia, where the government attempted to

foreclose judicial review through procedural barriers

rather than confronting the substance of constitutional

claims through a fair hearing before a neutral

tribunal.

8

REASONS FOR GRANTING THE WRIT

This petition presents important constitutional

questions warranting this Court's review. The lower

courts' dismissal of Petitioner's claims without any

evidentiary hearing, despite sworn allegations of

governmental retaliation that could not lawfully be

resolved on the written record alone, raises serious

concerns regarding the protection of due process rights

under the Fifth Amendment. The refusal to address

motions for recusal despite documented institutional

connections implicates the appearance-of-bias

standard articulated in Caperton v. A.T. Massey Coal

Co., 556 U.S. 868 (2009). And the issuance of summary

orders without any statement of reasoning prevents

meaningful appellate review and undermines the

constitutional guarantee of access to the courts

reaffirmed in Noem v. Abrego Garcia, No. 24A949

(2025).

Note: The public significance of Petitioner's claims

is further demonstrated by more than 475 individuals

who have signed a public petition supporting

investigation of the underlying allegations. A QR code

and hyperlink providing direct access to that petition

and supporting documentation are included in the

Appendix for the Court's reference.

I.

The Denial of Any Evidentiary Hearing

Violated the Fifth Amendment's Guarantee

of Due Process

This Court has long held that due process

9

requires more than the opportunity to submit written

arguments when material facts are in dispute and

liberty interests are at stake. In Goldberg v. Kelly, 397

U.S. 254, 269 (1970), the Court explained that "[i]n

almost every setting where important decisions turn

on questions of fact, due process requires an

opportunity to confront and cross-examine adverse

witnesses." Similarly, in Londoner v. City of Denver,

210 U.S. 373, 386 (1908), the Court declared that "a

hearing in its very essence demands that he who is

entitled to it shall have the right to support his

allegations by argument however brief, and, if need be,

by proof, however informal."

Here, Petitioner's allegations go to the heart of

governmental accountability. Petitioner alleged—and

supported with sworn affidavits—that federal agents

abandoned promised witness protection, falsely

characterized him as a terrorism suspect, coordinated

with private actors to fabricate sabotage allegations,

and engaged in ongoing surveillance and harassment

that caused documented medical harm. Petitioner

identified specific individuals, dates, and incidents,

including the March 5, 2015 staged automobile crash.

These are not conclusory claims; they are factual

allegations requiring testimony and cross-examination

to resolve.

The district court never held a hearing. The First

Circuit affirmed without addressing whether

Petitioner was entitled to one. This case is

indistinguishable in principle from Townsend v. Sain,

372 U.S. 293, 312 (1963), where this Court held that

10

an evidentiary hearing is required when "the merits of

the factual dispute were not resolved in the state

hearing" and "the material facts were not adequately

developed." It is also consistent with this Court's

recent reaffirmation in Abrego Garcia that due process

demands "effective relief through facilitation of... the

opportunity to argue the case in court" and cannot rest

on written submissions alone when liberty is at stake.

II.

The Denial of Recusal Motions Despite

Documented Institutional Connections

Created an Appearance of Bias Too High to

Be Constitutionally Tolerable

The Fifth Amendment's due process guarantee

includes the right to an impartial tribunal. In re

Murchison, 349 U.S. 133, 136 (1955). This Court has

held that recusal is required not only when actual bias

is proven, but when "the probability of actual bias on

the part of the judge ... is too high to be

constitutionally tolerable." Withrow v. Larkin, 421

U.S. 35, 47 (1975); Caperton v. A.T. Massey Coal Co.,

556 U.S. 868, 877 (2009).

Here, Petitioner moved for recusal based on the

presiding judge's documented professional connections

to officials named in Petitioner's related federal filings,

including former Special Counsel Robert Mueller, as

well as the appearance of structural bias arising from

overlapping institutional ties between Massachusetts

federal judges and Department of Justice leadership.

Petitioner also presented evidence—obtained from a

credible law enforcement source through a private

11

investigator—that communications concerning

Petitioner's cases circulated within the Boston FBI

Field Office and were understood internally as matters

involving DOJ reputation and exposure.

The district court denied these motions without

explanation. The First Circuit never addressed them.

Under Caperton, the failure even to acknowledge the

appearance-of-bias issue is itself a constitutional

violation. Where federal agencies named as defendants

have overlapping institutional ties to the judicial

officers presiding over the case, and where internal

law enforcement personnel are aware of and

discussing the litigation, the appearance of structural

bias becomes constitutionally intolerable. This Court's

review is warranted to clarify the recusal standard in

cases involving institutional defendants and the

judiciary's own structural relationships.

III. The Failure to Provide Any Reasoning in the

Judgments Below Violated Due Process and

Undermined Meaningful Appellate Review

Due process requires not only a hearing, but also

a reasoned explanation of the decision. See Joint AntiFascist Refugee Comm 'n v. McGrath, 341 U.S. 123,136

(1951) (Frankfurter, J., concurring) ("[T]he conclusion

must... be supportable as a matter of reason."). This

Court has repeatedly emphasized that summary

dispositions must not become a vehicle for avoiding

difficult constitutional questions. Griffin v. Illinois,

351 U.S. 12, 20 (1956).

12

Here, the First Circuit's October 16, 2025

judgment consists of a single paragraph invoking

summary affirmance under circuit rule, with no

indication whether Petitioner's claims were rejected on

timeliness grounds, jurisdictional grounds, procedural

grounds, or on the merits. The December 16, 2025

order denying rehearing is equally opaque: it states

only that the panel denied rehearing and that a

majority of active judges did not vote for en banc

review.

Petitioner is left unable to determine what legal

standard was applied, what facts were considered

material, or whether his constitutional arguments

were ever addressed.

This Court recently confronted a similar pattern

of evasion in Abrego Garcia, where the government

sought to foreclose judicial review through procedural

barriers. The Court held that the Constitution requires

"effective relief' and cannot tolerate governmental

action that leaves individuals unable to obtain a

meaningful forum for their claims. The same principle

applies here: a judiciary that refuses to explain its

decisions has effectively closed the courthouse door.

IV. This Case Reflects a Broader Pattern of

Institutional Protection That Warrants This

Court’s Attention

Petitioner respectfully submits that the facts of

this case implicate concerns larger than the disposition

of a single appeal. Massachusetts has experienced

13

multiple large-scale institutional crises in recent

years—including the Whitey Bulger corruption

scandal, the Dookhan and Farak drug-lab collapses,

and recent high-profile cases involving allegations of

law enforcement misconduct and cover-ups. These

crises have demonstrated how overlapping

institutional relationships can create structural

barriers to accountability.

Petitioner's concerns about systemic dysfunction

are not isolated. A long-serving federal judge in

Massachusetts recently resigned from the bench and

publicly stated that "silence, for me, is now

intolerable," citing deep concerns about erosion of the

rule of law and misuse of governmental authority.

According to published interviews and reporting, the

judge described institutional failures that have eroded

public trust and placed the judiciary in an untenable

position. While Petitioner does not allege misconduct

by any particular judge, the pattern of denials across

multiple courts, multiple judges, and multiple

proceedings—without a single evidentiary hearing

permitted over more than a decade—suggests a

systemic problem requiring this Court's attention.

The public has taken notice. More than 475

individuals have signed a public petition calling for

investigation of the matters Petitioner has raised. The

petition and supporting documentation are included in

the Appendix. This case presents an opportunity for

the Court to reaffirm that the appearance of

institutional bias—particularly where federal

defendants and federal judges share overlapping

14

professional networks—is constitutionally intolerable,

and that the denial of evidentiary hearings in cases

involving credible allegations of governmental

retaliation violates the bedrock principle that due

process requires more than paper submissions.

V.

The Dismissal on the Papers Raises Serious

Concerns Regarding Erosion of the Seventh

Amendment Right to Trial by Jury

While this case was dismissed at the Rule 12 and

Rule 60(b) stages before reaching trial, the manner of

dismissal raises broader concerns about the erosion of

the Seventh Amendment guarantee. When factual

disputes material to constitutional claims are resolved

against a plaintiff without any opportunity for jury

trial—or even an evidentiary hearing before a

judge—the practical effect is the extinguishment of the

jury right before it can ever vest. This Court has

recognized that dismissal procedures must not be used

to circumvent the Seventh Amendment's protection.

Duncan v. Louisiana, 391 U.S. 145, 157 (1968).

Petitioner does not contend that he had a vested

jury-trial right at the motion-to-dismiss stage. Rather,

Petitioner submits that the pattern of dismissing

sworn allegations involving disputed material facts—

particularly allegations of governmental misconduct

and retaliation —without permitting any factual

development threatens to render the Seventh

Amendment a nullity in cases where the government

is the defendant. This concern is especially acute

where, as here, multiple federal courts over more than

15

a decade have declined to permit even a single hearing,

effectively foreclosing any possibility that a jury could

ever be convened.

CONCLUSION

Petitioner has been effectively denied access to

the courts through a pattern of summary dismissals

spanning multiple federal actions, multiple courts, and

more than a decade of litigation. Despite sworn

allegations of governmental retaliation, threats to

personal safety, and documented medical harm, no

federal court has ever permitted Petitioner to present

witnesses, testify under oath, or introduce evidence

through live testimony. The lower courts' refusal to

address motions for recusal despite documented

institutional connections, combined with their failure

to provide any reasoning for the judgments entered,

violates the core due process principles reaffirmed by

this Court in Noem v. Abrego Garcia and Caperton v.

A.T. Massey Coal Co.

As this Court stated in Wisconsin v.

Constantineau, 400 U.S. 433, 437 (1971), "Where a

person's good name, reputation, honor or integrity is at

stake because of what the government is doing to him,

notice and an opportunity to be heard are essential."

Petitioner has been stigmatized by the very pursuit of

justice, branded as a suspect when he was in fact a

whistleblower, and denied the most basic procedural

safeguard: the chance to be heard before a neutral

tribunal.

16

The Court should grant certiorari to clarify that

due process requires evidentiary hearings when

material facts are in dispute, that the appearance of

institutional bias is constitutionally intolerable, and

that summary affirmances without reasoning do not

satisfy the constitutional requirement of meaningful

appellate review. For the foregoing reasons, this Court

should reverse the judgment of the First Circuit and

remand for proceedings consistent with the Fifth

Amendment's guarantee of due process.

\y Irvmg F. Rounds jZ'

Petitioner (Pro Se)

48 N. Sturbridge Road, Apt. B

Charlton, MA 01507

781-504-8974

roundsmechanical5@protonmail.com

Dated. March 12, 2026

IQM44037037

United States Supreme Court

Recfpieit

Clerics Office

Sender

Lisa Nicholson

Processed:

3/12/2026 8:42:38 PM | 514

17

RECEIVED

MAR 16 2026

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