1. Whether a state 's application of an expert-affidavit requirement to dismiss a
claim of extreme and obvious medical battery —where a doctor non-consensually
destroyed healthy genital tissue with a cryogen —violates the Fourteenth
Amendment 's Due Process Clause by creating an arbitrary and insurmountable
barrier to justice for indigent litigants.

2. Whether a state court 's ruling that deliberate, catastrophic damage to a patient 's
genitals constitutes merely "treatment of the correct organ, the skin " violates the
Equal Protection Clause by trivializing male sexual trauma and bodily integrity in a
way that would be legally unthinkable for female patients.

3. Does the Fourteenth Amendment permit a state court to effectively grant
hospitals and physicians immunity from battery claims by deeming any outcome, no
matter how grievous or non-consensual, as per se compliant with an indefensible
"standard of care "

4. Whether a state, through its judicial and medical actors, violates the Fourteenth
Amendment 's guarantee of due process and equal protection by systematically
exploiting a patient 's sexual humiliation —compelling the exhibition of intimate
trauma as a precondition for justice, only to then dismiss that evidence as trivial —
thereby inflicting a second, institutionalized injury and denying any meaningful
remedy for severe bodily and dignitary harm.

5. Whether a state violates the Seventh Amendment right to a jury trial (as
incorporated by the Fourteenth Amendment) by invoking a procedural rule to
dismiss a claim of severe frostbite injury —a condition universally recognized as an
obvious harm by laypersons —solely because the instrument of injury was wielded
by a physician, thereby creating an unconstitutional physician-specific exception to
the state 's own "obvious occurrence " rule.

Whether a state's application of an expert-affidavit requirement to dismiss a claim of extreme medical battery violates the Fourteenth Amendment's Due Process Clause by creating an arbitrary barrier to justice for indigent litigants