1.) Whether the lower courts ' orders allowing Respondent
to take, possess and use Petitioner 's property for the
public good without paying compensation for that
use are manifestly unjust and are far departures
from the accepted and usual course of judicial
proceedings, when the lower courts ignored the
clear grant of subject matter jurisdiction found in
28 U.S.C. §1491(a)(l) that includes claims based on
the U.S. Constitution and a contract with the United
States, when they ignored this Court 's longstanding
guidance on considering a motion to dismiss and
when they improperly shifted the burden of proof for
Respondent 's defenses to Petitioner?

2.) Whether the Due Process and Takings Clause is
self-executing (i.e., a cause of action arising directly
under the U.S. Constitution) or requires a statute to
justify its enforcement, when Respondent exercised
its power of eminent domain and took possession of
Petitioner 's property and the lower courts concluded
that they lacked subject matter jurisdiction over
Petitioner 's claim for compensation, despite Petitioner
clearly raising the Due Process and Takings
Clause issues in Petitioner 's complaint? Although
the Supreme Court of the United States ("this
Court ") specifically identified this issue as not being
addressed in Devillier, et al. v. Texas, 601 U.S. 293
(2024), the current dispute presents that issue with
a very straightforward and clean set of facts, where
Petitioner 's sole avenue for pursuing his compensation
claims against Respondent is in federal court.

3.) Whether the lower courts properly concluded that a
vague and undefined 'national security ' exception to
the Takings Clause exists (despite the clear historical
context of the Takings Clause being a direct response
to Britain 's compelled use of private property owned
by the colonials) sufficient to override Respondent 's
constitutional obligation to pay just compensation
for Respondent 's multi-year possession, control and
use of Petitioner 's property to sanction Russia for its
invasion of Ukraine (i.e., forcing Petitioner to bear
that public burden which should be borne by the public
as a whole)?

4.) Whether the lower courts properly expanded the
narrow 'illegal possession ' exception to the Takings
Clause to include Respondent 's illegal failure to
pay for the taking and use of Petitioner 's property,
when that expansion completely negates the Takings
Clause, because every violation of the Takings Clause
involves the failure to pay just compensation?

5.) Whether the lower courts properly expanded the
scope of the 'mere silence ' defense to Petitioner 's
breach of contract claim to include Respondent 's overt
acts confirming Respondent 's acceptance despite
the longstanding judicial precedents that overt acts
indicate the acceptance of an offer, when Petitioner 's
offer required acceptance by conduct, Petitioner 's
offer was accepted by Respondent 's conduct and
Respondent failed to remain 'merely silent ' in the face
of Petitioner 's offer?

Whether the lower courts improperly dismissed a takings claim involving property seized for national security purposes without providing just compensation