Borrowing the form of Justice Alito's framing of the question presented in Dobbs v. Jackson Women's Health Organization, No. 19-1392 (June 24, 2022), in this case "[t]he critical question is whether the Constitution, properly understood, confers a [private right of action against an individual State when that State itself violates the explicit prohibitions against slavery and involuntary servitude of Section 1 of U.S. Const. amend. XIII]" by and through a State-employed probation and parole officer who makes personal sex slaves of female probationers and parolees while they are in the State's care and custody.

Whether the Constitution confers a private right of action against an individual State when that State violates the explicit prohibitions against slavery and involuntary servitude of Section 1 of U.S. Const. amend. XIII