Here is the petition — Wolfchild En Banc Petition

An excerpt:

this appeal requires an answer to the following precedent-setting questions of exceptional importance:

(1) Should en banc review be granted when a panel’s analysis fails to follow principles of statutory construction resulting in the re-construction of Indian trust law contradicting Supreme Court and Federal Circuit precedent?

(2) Should en banc review be granted when a panel’s decision fails to apply recent Supreme Court precedent relating to Indian trust law beneficiaries and contradicts long-settled principles of law regarding termination of Native American trusts?