1. Whether the Merit Systems Protection Board
(MSPB) violated its statutory jurisdiction and due
process obligations by failing to provide Petitioner with
adequate notice of her right to challenge the validity
of federal employee insurance premium overpayments
in federal court, as required by the Due Process Clause
and Supreme Court precedent.

2. Whether the Federal Circuit erred in affirming
MSPB 's dismissal of Petitioner 's claims, thereby fore
closing judicial review of agency actions affecting sub
stantial property interests, contrary to Supreme Court
authority and the strong presumption in favor of judi
cial review of administrative action.

3. Whether the Merit Systems Protection Board
and the Federal Circuit Court of Appeals erred by
refusing to address, or refer to the appropriate forum,
Ms. Lucas 's colorable statute of limitations defense to
the Office of Personnel Management 's overpayment
recovery efforts —despite clear Supreme Court prec
edent that statutes of limitations serve as jurisdictional
bars to untimely government claims —and whether such
refusal violates the Board 's and the Court 's obligations
to act in accordance with law and afford individuals a
meaningful opportunity to assert their rights.

4. Whether the Merit Systems Protection Board
and the Federal Circuit Court of Appeals violated their
statutory and constitutional obligations by failing to
consider and apply the Board 's own controlling prece
dent in Arthur I. Martin v. Office of Personnel Manage
ment, 97 M.S.P.R. 303 (2004) —which requires recal
culation of alleged overpayments subject to a 10-year
limitation and reconsideration of waiver requests —
when adjudicating Petitioner Cambra L. Lucas 's chal
lenge to OPM 's overpayment recovery efforts, thereby
depriving her of the benefit of established Board prac
tice, correct jurisdictional analysis, and a meaningful
opportunity to assert her rights, in contravention of
the Due Process Clause and Supreme Court authority.

Whether the Merit Systems Protection Board (MSPB) violated its statutory jurisdiction and due process obligations by failing to provide adequate notice of the right to challenge federal employee insurance premium overpayments in federal court