1. Whether the challenged legislation, called the Consumer Directed Personal Assistance Program Amendment, which permanently extinguishes the contracts of hundreds of small businesses as of April 1, 2025, renders them completely valueless, provides no compensation for doing so, and is neither reasonable nor necessary to advance a significant and legitimate public purpose, violates the Takings and Contracts Clauses of the United States Constitution, both facially and as applied to Applicants.

2. Whether the courts below erred in departing from this Court's well-settled holdings that parties have a protected property interest in their contracts and instead concluding that certain contracts—private contracts in which the contractual counterparty receives state funding—are categorically exempt from this rule, such that this newly identified subset of contracts is not entitled to any protection under the Takings Clause and can be taken by the State without compensation.

3. Whether the courts below erred in employing the equivalent of rational basis review in evaluating a Contracts Clause claim, contrary to this Court's precedents, by wholly deferring to the State's bare assertion that a severe, industrywide nullification of existing contracts is justified by the purported—but unsubstantiated—resulting cost savings, thereby effectively rendering the Contracts Clause a dead letter.

Whether New York's legislation permanently extinguishing hundreds of small businesses' contracts for fiscal intermediary services in a home healthcare program, rendering them valueless without compensation and based on generalized cost savings, violates the Takings Clause and Contracts Clause of the Fifth and Fourteenth Amendments