1) Whether the applicable "plain and unambiguous " language in light of Hauser v.
IdahoDWP and of Congress 's federal statute 42 U.S.C. 1396a(aa) and 42 U.S.C. §
1396a(a)(10)(G)(XIV) ("BCCPTA "), or conforming Minnesota state Legislature 's
statute Mn.Stat.256B.057 Subd. 10(a)-(c) ("MA-BC ") requires-or even
allows--removal of Victoria as a patient in these government breast cancer
treatment payment programs from her Medicaid MA-BC coverage (i) after her
husband 's 65th birthday in July 2016 when it was terminated; (ii), on her 65th
birthday November 11, 2016 when respondents say it could or should have been
terminated; or (iii) on July 1, 2017 to the present, when she has not yet finished
receiving her required cancer treatment. In light of Kizor and Azar, should a state
agency like MDHS be deferred to so much that they try to use the funds of a federal
program to overcome want of local funds endangering patients?

2) Whether in reviewing the appeal of the termination of MA-BC and transfer to the
medical assistance for the elderly by the Ramsey County respondents or Minnesota
DHS under the state 's Administrative Procedures Act Mn.Stat. 14.69, DHS and the
state courts violated the federal Medicaid requirement for a fair hearing 42 U.S.C.
1396(a)(3), and the constitutionally required procedural due process under the 14th
Am. Due Process Clause as set forth in this Court 's Goldberg v. Kelly, Regents v.
Roth; Pediatric Specialties v. ADHS (8th Cir.) and related cases when they deprived
Petitioners of their right to prior notice of the county 's action and the county 's
reasons for transferring Victoria and her spouse to a harsh spenddown to 20% below
cash-poor level each month instead of her cancer treatment coverage. Whether
Minnesota 's post-deprivation proceedings, relying on Matthews v. Eldrige and
various Minnesota due process practices have substantially remedied that initial
flawed procedure which deprived Victoria of her statutory entitlement and
Constitutional and fundamental rights?

3) Whether Petitioners under the APA may pursue remedies for violation of federal
Constitutional rights under 42 U.S.C. §1983 for damages (against the Ramsey
county respondents); or for declaratory or injunctive relief (against the Minnesota
DHS) for violation of constitutional rights-14th Am. (procedural, substantive due
process, equal protection, arbitrary and capricious denial and injury)-or privacy-in
the administration of Victoria 's MA-BC and BCCPTA coverage-and for requiring
unwarranted payments for her cancer treatment from both Victoria and Stephen
down to 80% of poverty income monthly to get benefits? Is Minnesota and Ramsey
County by §1983 required to pay Victoria right now her MA-BC benefits, and other
damages to be determined in further proceedings?

Whether the applicable language requires or allows removal of Victoria from Medicaid breast cancer treatment coverage