I. Should Courts extend the precedent of Jacobson v. Massachusetts, 197 U.S. 11 (1905), for the legal requirement that a vaccine licensed through HHS, that is mandated, be necessary, harm-avoidant, proportional and non-discriminatory, requiring individualized exemptions for those eligible and not suitable for vaccinations?

II. Whether the Second Circuit erred finding plaintiff failed to exhaust remedies for a claim "MMR causes autism," overlooking petitioner had exhausted below on the "MMR\TCV! causes autism" and "TCV causes autism" theories, and demonstrated the reliance necessary to prove fraud, and conspiracy to commit fraud, the Court found was lacking?

III. Whether the Second Circuit erred in declining primary jurisdiction over petitioner's Citizens Action against the Secretary, by creating an exhaustion requirement based on its policy view that FDA is better suited to adjudicate the §31 Citizens Action against the Secretary of HHS?

Whether courts should extend the precedent of Jacobson v. Massachusetts to require that a mandated vaccine be necessary, harm-avoidant, proportional and non-discriminatory, with individualized exemptions