Petition for Writ of Certiorari — Jean Dominique Morancy, Petitioner v. Sabrina Alex Salomon

FILED

MAY 1 2 2026

No. 26-l^(l

OFFICE OF THE CLERK

SUPREME COURT, US.

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JBuprme (Unurf nf 3&titeh $fartes

Jean Dominique Morancy,

Petitioner,

V.

Sabrina Alex Salomon,

Respondent.

On Petition for Writ of Certiorari to the Florida Sixth

District Court Of Appeal

PETITION FOR WRIT OF CERTIORARI

Jean Dominique Morancy, Pro se

13096 SW 53rd St.,

Miramar, Florida, 33027

(786) 523-3179

ubmoiedo@yahoo.com

I. Questions Presented

1. In Roman Catholic Archdiocese of San Juan v.

Acevedo Feliciano, 140 S. Ct. 696 (2020), this Court

held that courts may not use nunc pro tunc orders to

retroactively create jurisdiction (facts) where none

existed. Does a state appellate court violate the

Fourteenth Amendment’s Due Process Clause when it

affirms—via an unreviewable

Per Curiam

Affirmance—a trial court judgment entered nunc pro

tunc to a date when the trial court demonstrably

lacked subject matter jurisdiction?

2. Does Article V, § 3(b)(3) of the Florida Constitution,

which categorically prevents the Florida Supreme

Court from reviewing unwritten Per Curiam

Affirmances (PCAs), violate the Fourteenth

Amendment Due Process Clause as applied, when it

operates to permanently insulate structurally void

orders from state supreme court supervision, thereby

precluding an "adequate and independent state

ground" for denial of relief under Michigan v. Long,

463 U.S. 1032 (1983)?

3. May federal courts lawfully invoke Younger

abstention to permit the federal enforcement of void

state arrears (e.g., U.S. Treasury offsets and passport

revocation), or invoke the Rooker-Feldman doctrine to

dismiss related federal civil claims, when the

underlying state judgment is a nullity ab initio, or

does such application unconstitutionally incentivize

state tribunals to weaponize void orders without fear

of federal review?

i

II. Parties to the Proceeding

Petitioner is Jean Dominique Morancy, who was the

Appellant in the Florida Sixth District Court of Appeal.

Respondent is Sahrina Alex Salomon, who was the

Appellee in the Florida Sixth District Court of Appeal.

HL RULE 29.6 STATEMENT

Pursuant to Supreme Court Rule 29.6, Petitioner is a

natural person and have no parent, subsidiary, or

publicly held corporation owning 10% or more of their

stock.

IV. STATEMENT OF RELATED PROCEEDINGS

The following is a list of all proceedings in other courts

that are related to the case in this Court:

• Morancy v. Salomon, No. 23-12248 (Feb. 8, 2024)

reversed the dismissal ruling in case (6:23-cv-714).

• Morancy v. Salomon, 24-12505 (11th Cir. 2025)

Certiorari denied.

• Morancy v. Salomon, 6:23-cv-714-CEM-RMN, U.S

District Court for the Middle District of Florida.

• Morancy v. Salomon, No. SC2022-1531 (Nov. 15,2022)

• Morancy v. Salomon, No. SC2022-1602 (Nov. 23,2022)

• Morancy v. Salomon, No. SC2023-0603 (May 2, 2023)

• Morancy v. Salomon, No. SC2023-0496 (May 18,2023)

• Morancy v. Salomon, No. SC2023-0941 (Jun. 30,2023)

• Morancy v. Znosko et al (CACE23021874)

• Morancy v. Znosko, 399 So.3d 1270 (Fla. 4th DCA Nov.

14, 2024)

• Morancy v. Department of Revenue Circuit 17,

Broward Unit DOR, (4D2025-0239)

• Morancy v. Salomon, No. 6D2023-2155 (March 22,

2023)

• Morancy v. Salomon, No. 6D2023-2541 (May 11, 2023)

• Morancy v. Salomon, No. 6D2023-1645(June 15, 2023)

ii

• Morancy v. Salomon, 375 So. 3d 288 (Fla. 6th DCA

Oct. 31, 2023) Certiorari denied Morancy v. Salomon,

S. Ct. No. 23-963 (April 15, 2024)

• J. D. M. v. S. A. S, No. 6D2025-1500 (June 25, 2025)

• Morancy v. Salomon, No. 6D2023-3456 (December

2025) (subject of current certiorari).

With the procedural history before this Court set

forth, the following contents outline the petition’s

structure.

in

V.

TABLE OF CONTENTS WITH APPENDIX

I.

Questions Presented......................

i

II.

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

III.

RULE 29.6 STATEMENT...........................................ii

IV.

STATEMENT OF RELATED PROCEEDINGS..... ii

V.

TABLE OF CONTENTS WITH APPENDIX..........iv

VI.

TABLE OF CITATIONS............................................ vi

VII.

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

Vin.

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

DC

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

X.

CONSTITUTIONAL AND STATUTORY

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

XI.

STATEMENT................................................................2

A

The Void Judgments and Jurisdictional Defect: 3

B. Federal Consequences and the Fourth DCA’s

Nullity Finding:.............

....3

C.

The Nunc Pro Tunc Maneuver and PCA Shield: .4

D. The Weaponization of Federal Abstention

Doctrines:............................................................................4

XII.

REASONS FOR GRANTING THE WRIT............. .5

A The Categorical Bar on Florida State Supreme

Court Review of Per Curiam Affirmances Under

Article V, § 3(b)(3) Violates the Due Process Clause

and Cannot Serve as an "Adequate and Independent

State Ground."................................................................... .5

B. The Florida Sixth DCA’s Decision Directly

Defies Roman Catholic Archdiocese............................ 6

C. The Court Must Clarify That Younger and

Rooker-Feldman Cannot Be Used to Shield

Judgments That Are a Nullity Ab Initio..... ........

XIII.

....6

CONCLUSION..........................................................7

iv

APPENDIX TABLE OF CONTENTS

Appendix A — Sixth District Court of Appeal of Florida

per curiam opinion 6D23-3456 (Dec. 9,

2025)............................

la

Appendix B — Fourth District Court of Appeal of Florida

opinion 4D2025-0239 (Mar. 25, 2026)

2a

Appendix C — United States Court of Appeals for the

Eleventh Circuit (Case No. 24-12505)

(11th Cir. 2025)

4a

Appendix D — Ninth Judicial Circuit in and for Orange

County, Florida (Case No. 2019-DR16766-0).....

12a

Appendix E — Sixth District Court of Appeal of Florida

denial of rehearing case 6D23-3456 (Jan.

13, 2026)

31a

Appendix F — Florida

Department

certification of arrears

v

of

Revenue

32a

VI.

TABLE OF CITATIONS

Cases

Daniels v. State, 712 So.2d 765 (Fla. 1998)................. 2, 4

Lee v. Kemna, 534 U.S. 362 (2002)....................................5

Michigan v. Long, 463 U.S. 1032 (1983).......................... 5

Morancy et al v. Salomon et al, No. 24-12505 (11th Cir.

May 8, 2025)................................................................... 6

Morancy v. Dep't of Revenue, No. 4D2025-0239 (Fla. 4th

DCAMar. 25, 2026)....................................................... 1

Morancy v. Salomon, 375 So. 3d 288 (Fla. 6th DCA Oct.

31, 2023)......................................................................... 3

Roman Catholic Archdiocese of San Juan v. Acevedo

Feliciano, 140 S. Ct. 696 (2020)................................ 2, 6

Younger v. Harris, 401 U.S. 37 (1971)........

2, 5, 6

Rules

Fla. R. App. P. 9.130(f)....................................................... 3

Constitutional Provisions

U.S. Constitution, Amendment XIV, § 1.............

2, 6

Florida Constitution

Article V, § 3(b)(3).................................................. 2, 4, 5, 6

U.S. Code

28U.S.C. § 1257(a)......................

2

VII. PETITION FOR WRIT OF CERTIORARI

To the Chief Justice and Associate Justices of the

Supreme Court of the United States:

Petitioner, Jean Dominique Morancy, respectfully

petitions for a writ of certiorari to review the PCA of the

District Court of Appeal of Florida, Sixth District (App.

A. la).

VIII. OPINIONS BELOW

The per curiam affirmance of the District Court of

Appeal of Florida, Sixth District (Case No. 6D23-3456), is

unpublished and is reproduced in the Appendix at App.

A. page la.

The related opinion of the District Court of Appeal of

Florida, Fourth District (Case No. 4D2025-0239), is

currently unreported but is available at Morancy v. Dep't

of Revenue, No. 4D2025-0239 (Fla. 4th DCA Mar. 25,

2026), and is reproduced in the Appendix at App. B. 2a.

The related decision of the United States Court of

Appeals for the Eleventh Circuit (Case No. 24-12505) is

unpublished and is reproduced in the Appendix at App.

C. page 4a.

The underlying nunc pro tunc final judgment of the

Circuit Court of the Ninth Judicial Circuit in and for

Orange County, Florida, is unpublished and is

reproduced in the Appendix at App. D. page 12a.

IX. JURISDICTION

The decision of the Florida Sixth District Court of

Appeal was entered on December 9, 2025 (App. A). On

January 13, 2026, the Sixth District Court of Appeal

entered an order denying Petitioner’s motion for

rehearing and clarification and striking the motion for

rehearing en banc (App. E page 31a). Petitioner was

1

granted an extension of time to file this petition to May

13, 2026 (No. 25A1153). The jurisdiction of this Court is

invoked under 28 U.S.C. § 1257(a).

CONSTITUTIONAL AND STATUTORY

PROVISIONS INVOLVED

Pursuant to Supreme Court Rule 14.1(f), the

following constitutional provisions, federal rules, and

judicial precedents are involved in this case. Pertinent

text is set forth verbatim where applicable;

X.

U.S. Constitution, Amendment XIV, § 1: "...nor shall

any State deprive any person of life, liberty, or property,

without due process of law..."

Florida Constitution, Article V, § 3(b)(3): The Florida

Supreme Court (May review any decision of a district

court of appeal that expressly declares valid a state

statute, or that expressly construes a provision of the

state or federal constitution, or that expressly affects a

class of constitutional or state officers, or that expressly

and directly conflicts with a decision of another district

court of appeal or of the supreme court on the same

question of law.) This section of the Florida Constitution

categorically excludes unwritten PCAs).

Roman Catholic Archdiocese of San Juan v. Acevedo

Feliciano, 140 S. Ct. 696 (2020).

Daniels v. State, 712 So.2d 765 (Fla. 1998).

Younger v. Harris, 401 U.S. 37 (1971).

XI. STATEMENT

This case presents a fundamental crisis in appellate

due process (Amendment XIV, § 1). It demonstrates how

state courts can manipulate procedural rules and nunc

pro tunc orders to evade binding precedents of the Florida

State Supreme Court and the United States Supreme

Court, manufacture jurisdiction, and insulate legally void

2

judgments from both state supreme court review and

federal constitutional scrutiny.

A. The Void Judgments and Jurisdictional Defect:

• On August 14, 2023, the Orange County, Florida

paternity court held a final hearing. At that time, the

trial court wholly lacked subject matter jurisdiction to

enter a final order because two interlocutory appeals

(Nos. 6D23-1677 and 6D23-1323) were actively

pending before the Florida Sixth District Court of

Appeal. Those appeals were not disposed of until

October 2023. SeeMorancy v. Salomon, 375 So. 3d 288

(Fla. 6th DCA Oct. 31, 2023) Certiorari denied

Morancy u. Salomon, S. Ct. No. 23-963 (April 15,

2024).

Despite this absolute lack of jurisdiction, the trial

court entered an initial final paternity order on

August 29, 2023. On September 11, 2023, Petitioner

filed a notice of appeal (Case No. 6D23-3456, the

subject of this petition). Shockingly, three days later,

on September 14, 2023, the trial court entered a

"corrected” final judgment, despite the pending notice

of appeal and the still-pending interlocutory appeals.

See Fla. R. App. P. 9.130(f) (“[T]he lower tribunal may

not render a final order disposing of the cause pending

such review absent leave of the court.”)

B. Federal Consequences and the Fourth DCA's

Nullity Finding:

The collateral damage of these void orders was

immediate and severe. On May 8, 2024, the Florida

Department of Revenue certified arrears based on this

void corrected final judgment (App. F). Petitioner

requested an administrative hearing before an

administrative law judge. That request was not

honored but the hearing was held before an

administrative agent. The agent affirmed the

certification,

triggering

devastating

federal

3

consequences: referral to the U.S. Department of the

Treasury for Federal Tax Refund Offset, and the U.S.

Department of State for passport revocation.

Petitioner appealed this administrative affirmance

to the Florida Fourth District Court of Appeal. The

Fourth DCA correctly declared that the corrected final

judgment was a nullity during that time period due to

the jurisdictional defects (App. B page 2a).

C. The Nunc Pro Tunc Maneuver and PCA Shield:

While the Fourth DCA recognized the nullity, the

Sixth DCA orchestrated a maneuver to salvage it. In

a related federal action (Morancy et al. v. Salomon et

al, M.D. Fla. No. 6:23-cv-714), the district court denied

Petitioner an injunction. Petitioner moved for an

appeal to the Eleventh Circuit on August 2, 2024. A

mere forty minutes later, the Sixth DCA abruptly

relinquished jurisdiction to the state trial court. On

August 20, 2024, the trial paternity court re-entered

the exact same final judgment nunc pro time to

August 14, 2023—the very period it lacked

jurisdiction (App. D page 30a). The Sixth DCA

subsequently issued a Per Curiam Affirmance (PCA)

of this void nunc pro tunc order (App A page 1A).

Under Florida Supreme Court precedent, an appellate

court’s affirmance of a nullity is itself a nullity. See

Daniels v. State, 712 So.2d 765, 766 (Fla. 1998). Yet,

because Article V, § 3(b)(3) of the Florida Constitution

strips the Florida Supreme Court of jurisdiction to

review unwritten PCAs, the void order is now

permanently insulated from state supreme court

review.

D. The Weaponization of Federal Abstention

Doctrines:

Left with a state-court manufactured nullity carrying

severe federal consequences, Petitioner sought relief in

federal court. However, the federal courts invoked

4

Younger abstention (Younger v. Harris, 401 U.S. 37

(1971)) to deny an injunction against the enforcement of

the void arrears (App. C). Concurrently, Defendants in

the federal racketeering suit preemptively invoked the

Rooker-Feldman doctrine prior to the denial of the

injunction. Having already suffered a denial of injunctive

relief under Younger, Petitioner faces the imminent

threat that the federal district court will now seize upon

this void nunc pro tunc PCA as a "final state judgment"

to dismiss Petitioner's remaining federal claims.

XII.

REASONS FOR GRANTING THE WRIT

A. The Categorical Bar on Florida State Supreme

Court Review of Per Curiam Affirmances Under

Article V, § 3(b)(3) Violates the Due Process

Clause and Cannot Serve as an "Adequate and

Independent State Ground?

While Michigan v. Long, 463 U.S. 1032 (1983) protects

adequate and independent state grounds, a state

procedural rule cannot bar federal review when it

structurally operates to deny fundamental federal rights.

See Lee v. Kemna, 534 U.S. 362, 376 (2002).

Article V, § 3(b)(3) of the Florida Constitution

categorically deprives the state's highest court of

jurisdiction to review unwritten Per Curiam Affirmances

(PCAs). This absolute prohibition functions as an

impenetrable shield, trapping Petitioner—and all

similarly situated litigants—in a procedural black hole

where lower appellate courts can act arbitrarily without

fear of state-level checks and balances.

Because the Florida Supreme Court cannot ascertain

whether a lower court affirmed a structurally void

judgment without first possessing the jurisdiction to

review PCAs generally, the categorical ban itself is the

constitutional defect. When a lower appellate court issues

5

a PCA affirming a nullity, Article V, § 3(b)(3) mandates

judicial blindness, permanently insulating the error from

higher state supervision. This Court should grant

certiorari to hold that the absolute jurisdictional bar on

reviewing unwritten PCAs in Article V, § 3(b)(3) is

facially unconstitutional under the Fourteenth

Amendment’s Due Process Clause( Amendment XIV, § 1).

Consequently, this state procedural bar cannot serve as

an adequate or independent state ground to evade this

Court’s review.

B. The Florida Sixth DCA’s Decision Directly

Defies Roman Catholic Archdiocese.

Jurisdiction cannot be conjured retroactively. As this

Court held in Roman Catholic Archdiocese of San Juan v.

Acevedo Feliciano, 140 S. Ct. 696, 773 (2020) ("[n]unc pro

tunc orders are not some Orwellian vehicle for revisionist

history—creating ’facts' that never occurred in fact.”). A

nunc pro tunc order cannot validate actions taken

without jurisdiction. Because the trial court lacked

jurisdiction on August 14, 2023, the August 20, 2024 re­

entry of the order nunc pro tunc to that date is

structurally void. The Sixth DCA’s affirmance of this

order directly defies this Court’s precedent in Roman.

C. The Court Must Clarify That Younger and

Rooker-Feldman Cannot Be Used to Shield

Judgments That Are a Nullity Ab Initio.

Lower federal courts urgently need guidance on the

application of federal preclusion and abstention doctrines

to void state orders. In this case, the Eleventh Circuit

permitted the federal government to offset Petitioner's

taxes and deny a passport based on a void state order

under the guise of Younger abstention (Younger v. Harris,

401 U.S. 37 (1971)); See Morancy et al v. Salomon et al,

No. 24-12505 (11th Cir. May 8, 2025) (App. C page 4a11a). Concurrently, Defendants have preemptively

6

positioned a Rooker-Feldman defense, teeing up the

district court to dismiss Petitioner's federal racketeering

claims by treating the void state PCA as a legitimate

"final judgment.

xm. CONCLUSION

For the foregoing reasonguthe petition fm4a writ of

certiorari should be granted.

If t

/ Respefoftffiy submitted,

\jeahnj0KHni«ue Morancv

13096 SW 53rd St., Miramar, Florida, 33027

(786) 523-3179

ubmoiedo@vahoo.com

7