United States v. O'Donnell: Defendant-appellee’s motion to stay the Circuit Court’s mandate

Motion for a Stay of Issuance of the Mandate of Defendant-Appellee Pierce O’Donnell. Defendant argues that a certiorari petition by Defendant would present substantial and meritorious questions arising from the panel’s decision, including: (1) whether the Ninth Circuit interpreted provisions of the Federal Election Campaign Act (“FECA”) in accordance with Supreme Court precedent concerning statutory interpretation; (2) whether the panel opinion applied Fifth Amendment due process principles and the rule of lenity as required when interpreting a criminal statute; and (3) whether the panel opinion followed Supreme Court precedent concerning interpretation of statutes criminalizing otherwise constitutionally-protected political speech.