In any action or proceeding that a party believes is required to be heard by a three-judge
district court, the words “Three-Judge District Court Requested” or the equivalent shall be
included immediately following the title of the first pleading in which the claim for relief
requiring a three-judge court is pleaded. Unless the basis for the request is apparent from
the pleading, it shall be set forth in the pleading or in a brief statement attached thereto.
The words “Three-Judge District Court Requested” or the equivalent on a pleading is a
sufficient request under 28 U.S.C. § 2284.
