I.          Questions Presented For Review

 

A.        Where the court of appeals and the district court relied upon a previous Washington court decision deciding an issue of Washington law, App. pp. 3 and 9-10, to find federal law claims in a subsequent federal court action barred by collateral estoppel, does Washington collateral estoppel practice control, and if so, does Washington collateral estoppel practice limit the application of the doctrine to allow subsequent consideration of federal claims unnecessary for the adjudication of the previous Washington law claim?

 

B.         Does 42 U.S.C. §1994, the Antipeonage Act, by its inclusion of the word “orders”, create a statutory exception to the Rooker-Feldman doctrine, 28 U.S.C. §1738, res judicata, collateral estoppel, claim preclusion, issue preclusion, and 28 U.S.C. 2283, and does it provide the federal courts jurisdiction independent of any other statute?

 

C.        Are any attempts to coerce, by license suspension, a non-custodial parent’s consent to a “repayment agreement” when he possesses wealth insufficient to comply with the support order without employment, and the state statute, RCW 74.20A.320, that provides for such coercion, declared null and void by 42 U.S.C. §1994?

 

D.        As RCW 74.20A.320(3) prohibits consideration of inability to comply with a support order, is it a bill of attainder against parties unable to comply with such support orders prohibited by Article I Section 10 clause 1 of the Constitution?

 

E.         Can the litigation bar, App. pp. 17-20, affirmed App. p. 4, prohibiting new complaints by Mr. Knight challenging the child support order and statutory scheme while acting pro se in the federal courts based on frivolousness of claim be sustained after the California appellate courts annulled a finding of child support contempt on the basis that Mr. Brent Moss acted in good faith reliance on the Thirteenth Amendment and the Antipeonage Act?  After this Court invalidated a Wisconsin statute prohibiting the issuance of marriage licenses to non-custodial parents unable to comply with their support orders in Zablocki v. Redhail, (1978) 434 U.S. 374, 54 L. Ed. 2d. 618, 98 S. Ct. 673?

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