Access to the Supreme Court

1. Whether the D.C. Circuit erred by applying mandamus jurisdiction doctrine — which prohibits lower courts from compelling the Supreme Court's Clerk to act — to dismiss a constitutional due process claim challenging a completed administrative act: the Clerk's rejection of a petition for writ of certiorari without referral to any Justice, without process, and without any mechanism for judicial review. 2. Whether the Clerk of this Court, acting in a non-judicial administrative capacity, may reject a petition for writ of certiorari without referral to any Justice and without any reviewable process, in a manner that forecloses a citizen's constitutional right of access to this Court under the First and Fifth Amendments — particularly where the government has never been required to defend that practice in any adversarial proceeding.