Petition for Writ of Certiorari — Sherri Richardson, Petitioner v. Irongate Mutual Homes, Inc., t/a Pear Tree Park Townhomes

Supreme Court, U.S.

FILED

SUPREME COURT OF THE UNITED STATES

SEP 1 3 2025

OFFICE OF THE CLERK

SHERRI M. RICHARDSON

Petitioner

Vs

IRONGATE MUTUAL HOMES, INC. t/a PEAR TREE PARK TOWNHOMES

Respondent

ON PETITION FOR A WRIT OF CERTIORARI TO THE

UNITED STATES COURT OF APPEALS FOR THE FOURTH

CIRCUIT CASE NUMBER: 24-2238

PETITION FOR A WRIT OF CERTIORARI

Sherri Richardson

164 Motoka Dr., Unit 5

Newport News, VA 23602

Petitioner Pro Se

1. QUESTION PRESENTED

I.

WHETHER THE APPELLATE COURT ERRED IN AFFIRMING

THE DISTRICT COURT’S RULING THAT THAT FEDERAL

QUESTION JURISDICTION AND PROCEDURAL

CONSIDERATIONS DID NOT EXIST?

II.

WHETHER THE COURTS BELOW ERRED BY IGNORING

AUTHORITY SUPPORTING FEDERAL JURISDICTION OVER

COUNTERCLAIMS ALLEGING FEDERAL LAW VIOLATIONS?

I

TABLE OF CONTENTS

TABLE OF CONTENTS.................................................. II

QUESTION PRESENTED...................................................... I

PARTIES TO THE PROCEEDING............................. Ill

TABLE OF AUTHORITIES......................................... Ill

PETITION FOR WRIT OF CERTIORARI........................ 1

OPINIONS BELOW................................................................. 1

JURISDICTION....................................................................... 1

CONSTITUTIONAL PROVISIONS INVOLVED............. 2

PROCEDURAL HISTORY AND STATEMENT OF THE

CASE.......................................................................................... 2

REASONS FOR GRANTING THE WRIT...................... „ 11

CONCLUSION..................................................................... 21

CERTIFICATE OF SERVICE.............. ............................... 23

II

PARTIES TO THE PROCEEDING

Petitioner is the Defendant in this case and was

appellants in the court of appeals.

Respondent is the Plaintiff and were the

appellees in the court of appeals

TABLE OF AUTHORITIES

Cases

Akin v. Ashland Chemical Co., 156 F.3d 1030 (10th Cir. 1998),

15

Benavidez v. Sandia National Labs., 212 F. Supp. 3d 1039, 1092 (D.N.M. 2016),

15

Caterpillar Inc. v. Williams, 482 U.S. 386 (1987),

23

Holmes Group, Inc. v. Vornado Air Circulation Sys., Inc., 535 U.S. 826 (2002),

23

In Grable & Sons Metal Prods., Inc. v. Darue Eng’g & Mfg., 545 U.S. 308

(2005),..

23

In re Blackwater Sec. Consulting, LLC, 460 F.3d 576, 584 (4th Cir. 2006),

13

Old Dominion Elec. Coop. v. PJM Interconnection, LLC, 24 F.4th 271, 279 (4th

Cir. 2022),

18

Quackenbush v. Allstate Ins. Co., 517 U.S. 706 (1996),

13

Thermtron Prods., Inc. v. Hermansdorfer, 423 U.S. 336 (1976),

13

Watford v. Heckler, 765 F.2d 1562, 1566 (11th Cir. 1985),

17

Palmer v. United States Internal Revenue Serv., 116 F.3d 1309, 1312 (9th

Cir. 1997)

7

United States v. Lane, 303 F.2d 1,4 (5th Cir. 1962)

17

Statu tes/Codes

28 U.S.C. §§ 1331 and 1332

................................................. 3

III

28 U.S.C. § 1447(d)........................................................................13

28U.S.C. § 1447(c).......................................................................13

RICO, 18 U.S.C. §§ 1961-1968.................................................... 20

Fifth Amendments to the US constitution.......................................... 3

14th Amendments to the US constitution.......................................... 4

IV

PETITION FOR WRIT OF CERTIORARI

Sherri Richardson, respectfully petitions the Supreme Court

for a writ of certiorari to review the judgment of the United States

Court of Appeals for the Fourth Circuit.

OPINIONS BELOW

Opinion and Judgment entered by Fourth Circuit Court on

May 19, 2025, which dismissed Appellant’s appeal for lack of

jurisdiction. Sherri Richardson’s Petition for Panel Rehearing in

the United States Court of Appeals for the Ninth Circuit was

denied on June 17, 2025 (ECF No. 21). Thereafter, on June 25,

2025, the Fourth Circuit issued its formal mandate, giving effect to

its May 19, 2025, judgment of dismissal (ECF No. 22). Those

orders are attached at Appendix ("App.") at 1.

JURISDICTION

Rehearing was denied on June 17, 2025 (ECF No. 21). On

June 25, 2025, the Fourth Circuit issued its formal mandate,

giving effect to its May 19, 2025, judgment of dismissal (ECF No.

22).

Sherri Richardson invokes this Court's jurisdiction under 28

U.S.C. § 1257, having timely filed this petition for a writ of

1

certiorari within ninety days of the United States Court of Appeals

for the Ninth Circuit Order denying the rehearing.

CONSTITUTIONAL PROVISIONS INVOLVED

United States Constitution, Amendment fifth and 28 U.S.C. §

1331.

This is the foundational constitutional authority for federal-question

jurisdiction under 28 U.S.C. § 1331. Your argument is that the District

Court ignored this constitutional mandate by Fifth Amendment - Due

Process Clause Protects against deprivation of property or rights without

due process of law. Improper remand without addressing binding

precedent or statutory provisions constitute a procedural due process

violation by depriving Petitioner of the right to have federal claims heard

in a federal forum.

PROCEDURAL HISTORY AND STATEMENT OF FACT

This matter stems from a civil action initiated by Plaintiff-

Appellee Irongate Mutual Homes, Inc., trading as Pear Tree Park

Townhomes on March 8, 2024, against Petitioner Sherri

Richardson in the Newport News Circuit Court.

On April 26, 2024, the Petitioner filed her Answer and

Counterclaim/ ECF No. 11-6).

On May 1, 2024, the Petitioner filed in the Circuit Court a

2

“Notice of Filing of Notice of Removal.” (ECF No. 11)

The action was subsequently removed by Richardson to the

United States District Court for the Eastern District of Virginia

(EDVA) under federal question and diversity jurisdiction pursuant

to 28 U.S.C. §§ 1331 and 1332.

On April 24, 2025, the EDVA issued an order remanding the

case back to the Newport News Circuit Court on the grounds that

it lacked subject matter jurisdiction (ECF No. 12).

Richardson promptly sought to appeal the remand by filing an

application for permission to appeal (ECF No. 14), which led to the

opening of her appeal in the United States Court of Appeals for the

Fourth Circuit under Case No. 24-2238 (ECF No. 16).

On May 19, 2025, the Fourth Circuit issued an unpublished

per curiam opinion dismissing Richardson’s appeal for lack of

jurisdiction, citing 28 U.S.C. § 1447(d)(ECF Nos. 18 & 19).

Subsequently, Richardson filed a petition for rehearing, which

was denied on June 17, 2025 (ECF No. 21). Thereafter, on June 25,

2025, the Fourth Circuit issued its formal mandate, giving effect to

its May 19, 2025, judgment of dismissal (ECF No. 22).

STATEMENT OF FACTS

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1. Appellant Sherri Richardson, a 53-year-old member-owner

of Irongate Mutual Homes, Inc., resides at 164 #5 Motoka Drive,

Newport News, VA 23602. The property in question is located at

174 Alan Drive, Newport News, VA 23602.

2. On February 1984, as an 11-year-old, Defendant/Appellant

moved with family into 163 #6 Alan Drive, a cooperative housing

community.

3. December 29, 2010, Defendant/Appellant purchased an

ownership interest in the community.

4. On March 2011, Defendant/Appellant attended the first

members-only Annual Board meeting and noticed violations of

standard shareholder meeting protocols. Drucker & Falk

employees were present, and their Regional Property Manager,

Cathy Epling, conducted the meeting instead of the Board of

Directors (BOD) President, as required by the ByLaws.

5. Defendant/Appellant raised this concern during the open

forum and was informed that Drucker & Falk had been “in charge

for a long time.”

6. Defendant/Appellant knew this was not permissible under

the law due to Defendant/Appellant's extensive corporate

4

experience and having operated a registered corporation since

2007.

7. Subsequently, Drucker & Falk employees Marsha Poston

and Cathy Epling, along with members of the BOD, labeled

Defendant/Appellant as a “problem in the community.” They began

to defame, harass, and threaten Defendant/Appellant, including

threats of illegal eviction and changing the locks on Defendant/

Appellant’s home. This harassment caused severe stress whenever

Defendant/Appellant had to leave for work or errands.

8. From 2011-2013, Defendant/Appellant knocked on the

doors of other owners to educate them about the ByLaws and

ownership rights. By 2013, largely due to Defendant/Appellant’s

efforts, all previous Board members were voted out and replaced

with individuals including Defendant/Appellant, Defendant/

Appellant’s mother Doris Richardson, Shuvonda Barnes, Candace

Serrette, and Daniel Lily.

9. The previous Board launched a campaign to defame and

discredit the new Board, partnering with Drucker & Falk to

conduct fraudulent, deceptive, and corrupt business practices to

instill fear in the community.

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10. In 2013, the prior Board held a meeting that violated the

ByLaws (e.g., the President did not call the meeting to order, and

the Secretary did not send notifications to members). This meeting

resulted in the reinstatement of the previous Board members.

11. The prior Board continued to defame, harass, and

threaten Defendant/Appellant and other Board members. Most

members became fearful of losing their homes if legal action was

pursued, but Defendant/Appellant persisted in defending

Defendant/Appellant’s legal rights.

12. In 2015, the first case against Defendant/Appellant was

filed. Marsha Poston intentionally delayed processing a housing

payment from Defendant/Appellant for nearly three weeks,

preventing Defendant/Appellant from voting in a critical annual

meeting.

13. An unlawful detainer was subsequently filed in Newport

News court.

14. On January 2017: Judge David F. Pugh ruled in

Defendant/Appellant’s favor.

15. Despite the ruling, the Board sent notices threatening to

evict Defendant/Appellant by changing the locks. Defendant/

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Appellant responded by warning that law enforcement would be

called if anyone attempted to enter Defendant/Appellant’s home.

16. Sometime in 2017, Defendant/Appellant, Deidra Sellers,

and Sharon Stewart filed a lawsuit against Irongate and the Board

in Baltimore, MD, where the cooperative was initiated.

17. The case was dismissed without prejudice for improper

venue, as the cooperative was registered in Annapolis, MD. The

group decided not to refile, opting instead to search for better legal

representation.

18. Sometime in 2019, Defendant/Appellant retained attorney

Cherie Harris of the Law Firm of Carteia Basnight, paying a

$3,000 retainer.

19. Ms. Harris hired a private investigator but later withdrew

from the case, transferring it to Ms. Basnight.

20. Ms. Basnight failed to notify the Board of her

representation, allowing the Board to continue defaming,

harassing, and threatening Defendant/Appellant.

21. When a second frivolous lawsuit was filed in 2022,

Defendant/Appellant hired Jeffrey Riddle after Ms. Basnight

declined to handle state court cases.

7

22. Mr. Riddle coerced Defendant/Appellant into signing

documents required by the Board, despite warnings that the

documents would be used against Defendant/AppeHant.

23. The Board later used these documents to file the current

case, as Defendant/Appellant had feared.

24. The ultimate goal of the Board is to unlawfully seize

ownership of the property from its rightful owners and resell it to

Drucker & Falk for personal profit. Appellant uncovered this

scheme during her tenure as a Board member and possess written

evidence to substantiate this claim. This is the primary reason

they are attempting to remove Appellant from the property.

Appellant demands that her ownership rights be respected under

the law, which conflicts with their corrupt, deceptive, and

fraudulent activities.

Discriminatory Approval Practices:

25. Appellant also discovered that the Board was approving

applications predominantly from Spanish-speaking immigrants,

including undocumented individuals, while systematically denying

applications from certain racial groups, including Black and White

applicants. This was a deliberate strategy to include individuals

unfamiliar with cooperative law, reducing resistance when the

8

property was eventually sold. Some Spanish-speaking members

were misled into believing they were renters, although they had

purchased memberships prior to the mortgages being paid off.

7/17/23 Meeting Irregularities:

26. The meeting was convened to discuss another increase in

housing charges, which members had neither voted on nor

supported.

27. Upon arrival, Appellant noticed the absence of the

customary sign-in book, which had been a standard practice since

2011. When appellant requested it, Board of Director Monte

Brown claimed it was unnecessary as no business was to be

discussed. However, the Board proceeded to discuss matters like

the insurance policy and budget, which appellant has on record.

Diversity Jurisdiction and Fraudulent Practices:

28. The cooperative’s original certificate indicates Maryland

incorporation, which was never properly terminated. The

transition to a Virginia corporation occurred without member

approval, violating bylaws and due process.

29. Appellant was coerced into signing disputed documents,

including the Occupancy Agreement and Civil Policy, after her

9

mortgage was paid off in 2012. These documents were fraudulently

created to undermine ownership rights.

30. The Board’s defamatory remarks in their complaint are a

continuation of their character assassination against Appellant

since 2011. Despite receiving a cease-and-desist notice on 9/27/23,

they have persisted in defamatory and harassing actions, causing

Appellant emotional and mental distress. They also ignored

multiple communications directing them to address all matters

through Appellant’s attorney.

31. Article 13 of the Occupancy Agreement was added without

a vote, violating the cooperative’s bylaws regarding amendments.

This renders the agreement legally void.

Unequal Enforcement:

32. The Board has not initiated actions against other

members, such as Xenia Tomlinson or Monte Brown, for their civil

policy violations. These individuals remain on the property,

highlighting discriminatory enforcement practices.

33. Other members who have violated policies will be

subpoenaed to corroborate Appellant’s claims.

10

Retaliatory Actions:

34.The Board has engaged in a pattern of retaliation,

defamation, and threats of eviction since 2012. They have spread

false information about Appellant to the community, portraying

Appellant as a troublemaker.

REASON FOR GRANTING THE WRIT OF CERTIORARI

This case is a superior vehicle for resolving a circuit conflict

on a well-defined legal issue of exceptional importance to the

national economy.

I.

THE APPELLATE COURT ERRED IN AFFIRMING

THE DISTRICT COURT’S RULING THAT FEDERAL

QUESTION JURISDICTION AND PROCEDURAL

CONSIDERATIONS DID NOT EXIST

a. Appellate Review Is Not Barred Where the District Court

Misconstrued Its Jurisdiction

Under Thermtron Prods., Inc. v. Hermansdorfer, 423 U.S. 336

(1976), overruled on other grounds by Quackenbush v. Allstate Ins.

Co., 517 U.S. 706 (1996), § 1447(d) only prohibits appellate review

when a remand is expressly based on § 1447(c)—namely, a lack of

subject matter jurisdiction or procedural defects in removal. See

also In re Blackwater Sec. Consulting, LLC, 460 F.3d 576, 584 (4th

Cir. 2006) (“We . . . look to the substantive reasoning behind the

11

order to determine whether it was issued based upon the district

court’s perception that it lacked subject matter jurisdiction.”).

Here, the district court analyzed the presence or absence of

federal-question jurisdiction under 28 U.S.C. § 1331 and diversity

jurisdiction under § 1332, finding neither. However, Appellant

Richardson raised substantial and non-frivolous federal

counterclaims, which implicated the court’s jurisdictional analysis.

The district court's framing of its order revealed potential

misapplication of that principle, not a straightforward

jurisdictional bar.

b. The Panel Misapprehended the Jurisdictional Basis Under

28 U.S.C. § 1332

The Opinion issued by this Court on May 19, 2025, dismissing

the appeal under 28 U.S.C. § 1447(d), fails to consider critical facts

that give rise to federal diversity jurisdiction under 28 U.S.C. §

1332 and thus warrant appellate review. The Panel concluded that

the remand order was unreviewable because it was based on a lack

of subject matter jurisdiction. However, that conclusion was based

on a misreading or mischaracterization of the underlying

jurisdictional issues.

12

Specifically, Appellant raised substantial questions

concerning the citizenship of the Plaintiff cooperative, Irongate

Mutual Homes, Inc., and the legitimacy of its corporate identity.

The cooperative's original certificate of incorporation indicates

formation under Maryland law. There is no evidence in the record

of a formal and lawful dissolution of the Maryland corporation or a

valid transition to a Virginia corporation. Critically, that purported

transition was executed without member approval, in violation of

the cooperative's own bylaws and governing documents.

The lack of procedural and substantive legitimacy in this

transition raises a colorable claim that the entity asserting state

citizenship in Virginia for purposes of defeating federal diversity

jurisdiction does not legally exist in that form. This fact alone

necessitates further scrutiny because it directly affects the

determination of whether complete diversity exists under § 1332.

By summarily concluding that jurisdiction was lacking without

addressing this foundational irregularity, the Panel

misapprehended the actual basis for federal jurisdiction.

c. Federal Jurisdiction and Enclave Doctrine

The property in question, located within a cooperative housing

community, involves governance and practices that intersect with

federal law. Under the federal enclave doctrine, federal courts have

13

exclusive jurisdiction over disputes arising in areas where the

United States exercises exclusive legislative authority. This

doctrine is well-established and supported by precedent, such as

Akin v. Ashland Chemical Co., 156 F.3d 1030 (10th Cir. 1998), and

Benavides v. Sandia National Labs., 212 F. Supp. 3d 1039, 1092

(D.N.M. 2016). The Defendant/Appellant’s claims implicate federal

questions, including allegations of constitutional violations and

fraudulent practices under cooperative housing laws.

d. Federal Enclave Jurisdiction Applies

The federal enclave doctrine grants exclusive jurisdiction to

federal courts over places within the United States where the

federal government exercises exclusive authority. Plaintiffs’

Motion notably fails to address this doctrine or the controlling

precedent confirming its applicability. As established in Akin v.

Ashland Chemical Co., 156 F.3d 1030, 1034 (10th Cir. 1998), and

Benavidez v. Sandia National Labs., 212 F. Supp. 3d 1039, 1092

(D.N.M. 2016), when events underlying a case occur within a

federal enclave, the entire lawsuit is removable to federal court

under federal question jurisdiction. Federal enclaves are areas in

which state law is preempted, and federal law governs.

Consequently, claims tied to events within these enclaves

inherently arise under federal law, granting this Court original

14

jurisdiction. Plaintiffs’ omission of this critical doctrine is a fatal

flaw in their argument for remand.

e. The Remand is Based on an Erroneous Assessment of

Jurisdiction

If the district court conflated procedural considerations or

misapplied controlling law in concluding that it lacked jurisdiction

—particularly in light of Richardson’s invocation of federal law in

her pleadings—this Court retains jurisdiction to review the order.

See Watford v. Heckler, 765 F.2d 1562, 1566 (11th Cir. 1985)

(appellate review permitted when the district court’s remand was

based on erroneous legal conclusions about jurisdiction).

A remand based on mischaracterizing federal counterclaims

or misapplying § 1331 jurisprudence does not constitute a

jurisdictional defect under § 1447(c) and should not be shielded

from review under § 1447(d). Thus, the panel’s dismissal for lack of

jurisdiction forecloses a meritorious challenge to the district court's

legal error.

f. Certiorari Is Warranted to Prevent a Manifest Misapplication

of Law

The panel’s ruling effectively expands the reach of § 1447(d) to

immunize legal errors in jurisdictional assessments from appellate

review. This is inconsistent with Supreme Court precedent and

this Circuit’s own standard that mandates reviewing the

15

“substantive reasoning” of the remand order to determine its true

jurisdictional basis. See Blackwater, 460 F.3d at 584.

Given that Richardson’s appeal arguably presented a

reviewable legal issue—i.e., whether the district court misapplied

federal-question and diversity standards—dismissal of the appeal

was improper. Rehearing is necessary to correct this error and

ensure proper application of § 1447(d) and related jurisprudence.

II.

THE PANEL OVERLOOKED THE IMPACT

OF FRAUDULENT CONDUCT ON

JURISDICTIONAL ANALYSIS.

Further, the Court's opinion did not account for well-pleaded

allegations of fraud, coercion, and due process violations, which

directly affect the character and validity of the underlying state

court proceedings. Contrary to the Fourth Circuit’s reliance on Old

Dominion Elec. Coop. v. PJM Interconnection, LLC, 24 F.4th 271,

279 (4th Cir. 2022), this case is not a typical removal premised

solely on counterclaims. Appellant's assertions of federal

jurisdiction arise in part from fraudulent practices that nullify the

validity of the plaintiff's claims and the documents they rely upon.

Specifically:

16

Petitioner was coerced into signing post-mortgage

agreements, including a Civil Policy and Occupancy Agreement,

which were neither presented at the time of original purchase nor

supported by any lawful obligation. These documents were

fabricated after the fact to undermine Appellant’s vested property

interests.

The Board’s unilateral addition of Article 13 to the Occupancy

Agreement, without a member vote, constituted a material and

illegal alteration of contract terms, further supporting a claim that

the cooperative’s lawsuit is premised on void or fraudulent

instruments.

The cooperative’s litigation conduct includes a longstanding

pattern of harassment, character defamation, and disregard of

legal representation, culminating in emotional harm and

constitutional due process concerns. The district court and this

Panel ignored these factors, which implicate federal questions

related to due process and property rights.

g- RICO Violations by Appellee

The appellant asserts that the Plaintiff/Appellees, including

the Newport News City Assessor and Drucker & Falk (D&F), have

engaged in a pattern of racketeering activity in violation of the

17

Racketeer Influenced and Corrupt Organizations Act (RICO), 18

U.S.C. §§ 1961-1968. This pattern of activity demonstrates their

intent to fraudulently convert the appellant's community from

townhomes to apartments, a scheme that is part of a larger

conspiracy to sell the property and redevelop it without the owners'

consent.

The Newport News City Assessor, acting at the behest of

Drucker & Falk and the Board of Directors (BOD), reassessed the

appellant's community as apartments despite the fact that the

dwellings are townhomes. This reclassification directly contradicts

the legal and structural definition of the property and

demonstrates the Plaintiff's intent to misrepresent the nature of

the community to facilitate redevelopment. Recorded conversations

with the Assessor confirm that Drucker & Falk influenced this

reassessment, illustrating their role in this fraudulent activity.

Apartments is defined as suites of rooms forming individual

residences within a larger building containing multiple such

residences. Townhomes is Multi-story homes attached to at least

one other unit, sharing walls but retaining distinct ownership. The

community comprises two-level dwellings that conform to the

definition of townhomes, with no structures resembling apartment

buildings. Despite this, the community is now improperly fisted as

18

apartments in the postal system, further evidencing the fraudulent

conduct.

Drucker & Falk, in conjunction with the BOD, have engaged

in a consistent pattern of fraudulent and corrupt activities aimed

at advancing their conspiracy. Specific acts include:

a. Drucker & Falk employee Rose Hewitt intentionally

perjured herself during the 2015 unlawful detainer hearing, falsely

claiming that the appellant was a renter rather than an owner.

This perjury was an attempt to secure the appellant’s eviction and

further their scheme.

b. Employees of Drucker & Falk, including Rose Hewitt,

Victor Fontanez, and former employee Cathy Epling, have

harassed and threatened the appellant over several years. Ms.

Hewitt explicitly stated her intent to ensure the appellant's

eviction, demonstrating malice and coordinated efforts to

intimidate dissenters.

c. The Appellee’s actions, including the fraudulent

reclassification of the property, harassment of owners, and

documented statements, establish their intent to sell the land and

redevelop the community as apartments. These actions violate 18

U.S.C. § 1962(c), which prohibits conducting or participating in the

19

affairs of an enterprise through a pattern of racketeering activity,

and § 1962(d), which prohibits conspiring to do so.

The Plaintiffs’ actions constitute a federal question of law as

they involve violations of RICO, a federal statute designed to

combat organized and systemic fraud. The pattern of fraud,

harassment, and conspiracy to misrepresent property ownership

and classification qualifies as racketeering activity under 18

U.S.C. § 1961(1), which includes mail fraud, wire fraud, and

obstruction of justice. The appellant seeks relief under RICO to

address these systemic violations.

III.

DISTRICT COURT ERRED BY IGNORING

AUTHORITY SUPPORTING FEDERAL

JURISDICTION OVER COUNTERCLAIMS

ALLEGING FEDERAL LAW VIOLATIONS

The District Court committed reversible error by failing to

cite any authority on whether a counterclaim alleging violations of

federal law is subject to remand, and the Plaintiff offered none to

the contrary. This omission undermines the legal basis for remand.

a. Federal Jurisdiction Over Counterclaims

Even assuming the Plaintiffs complaint raises no federal

question, the Defendant’s counterclaims alleging federal law

violations independently established jurisdiction under 28 U.S.C. §

1331. In Grable & Sons Metal Prods., Inc. v. Darue Eng’g & Mfg.,

20

545 U.S. 308 (2005), the Supreme Court held that federal courts

have jurisdiction when a substantial federal issue is necessarily

raised. The District Court failed to apply this principle or consider

Holmes Group, Inc. v. Vornado Air Circulation Sys., Inc., 535 U.S.

826 (2002), and Caterpillar Inc. v. Williams, 482 U.S. 386 (1987),

which recognize the jurisdictional significance of federal

counterclaims.

b. The controversy exceeds $75.000

The amount in controversy exceeds $75,000 under 28 U.S.C. §

1332(a), as evidenced by $107,352 in housing payments over 14

years, plus the value of Defendant’s ownership interest. The

Plaintiff did not dispute these figures.

c. Removal of Counterclaims

The District Court ignored 28 U.S.C. § 1446, which allows

removal based on counterclaims raising federal issues. Plaintiffs

assertion that counterclaims cannot create federal jurisdiction

lacks statutory or precedential support.

d. Plaintiff’s Failure to Rebut

The Plaintiff’s motion to remand conspicuously ignored

binding legal doctrines and failed to cite contrary authority.

CONCLUSION

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For the foregoing reasons, Petitioner Sherri Richardson

respectfully requests that this Court issue a writ of certiorari to

review the judgment of the Fourth Circuit Court of Appeals.

Respectfully submitted, this

.2025,

Sherri Richardson

(Pro se Petitioner )

22