1) Whether, to properly plead a procedural due process claim under the Fourteenth Amendment, a plaintiff must allege a government actor had actual or constructive knowledge that he or she unlawfully deprived the plaintiff of life, liberty, or property.

2) Whether the government violates its employees' First Amendment rights by seizing union dues from their paychecks without affirmative consent shown by clear and compelling evidence.

3) Whether a union engages in "state action" when it uses a statutory privilege granted to it by a state and a municipality to access employees' paychecks through a public employer's union dues payroll deduction system.

Whether the government violates employees' First Amendment rights by seizing union dues without affirmative consent and whether a union's use of a statutory privilege constitutes state action