Discrimination Supreme Court denied petition for certiorari where 3d Circuit dismissed pro se complaint for failure to state a claim upon which relief can be granted. Complaint alleged violations of the Americans with Disabilities Act, and Titles VI and VII of the Civil Rights Act of 1964. The District Court dismissed for failure to state a claim and granted leave to amend the complaint. Instead, complainant appealed to the Third Circuit, which determined that the appeal amounted to a waiver of complainant’s right to amend, and then affirmed the lower court’s dismissal. Alja-Iz v. Virgin Islands Bd. of Educ., 2016 U.S. Lexis 2101 (March 21, 2016).