jcutonilli
Ultimate Member
- Mar 28, 2013
- 2,474
SCOTUS petition for cert in 3.2.1...
I have not finished the entire argument yet, but I would file a motion for rehearing on the ground that they raised arguments not previously argued. I do not remember them raising any arguments about history and tradition prior to the last supplemental en banc brief. I am on pg 113 and all they talk about is the history and tradition. They admonished the plaintiffs for not raising issues at the district court, yet they allowed them to raise issues purely at the en banc court level.