1. KNOWING AND INTENTIONAL MISREPRESENTATION (Kousisis).
Whether the Sixth Circuit 's affirmance of wire-fraud convictions under 18 U.S.C.
§ 1343 conflicts with this Court 's requirement that the government prove a
knowing and intentional misrepresentation at the time property is obtained,
where the alleged "fraud " rested on the timing and sequencing of payments
later directed by the architect and owner under a financing structure that vested
the developer with discretion over drawdowns and disbursements; and where the
record shows the project was completed, the contractors were paid, and
Petitioner 's net contributions exceeded withdrawals. See United States v.
Kousisis, 145 S.Ct.1382 (2025); Neder v. United States, 527 U.S. 1,20-25 (1999)

2. REVIVAL OF RIGHT-TO-CONTROL (Ciminelli). Whether the Sixth Circuit
effectively revived the discredited "right-to-control " theory by upholding
convictions based on alleged breaches of "trust, " "expectations, " and "fiduciary
duty, " rather than a false statement obtaining money or property, in direct
conflict with Ciminelli v. United States, 598 U.S. 306,312-15 (2023), and
McNally v. United States, 483 U.S. 350,356-60 (1987).

3. MVRA RESTITUTION WITHOUT LOSS (Lagos). Whether the court of
appeals expanded the Mandatory Victims Restitution Act, 18 U.S.C. § 3663A,
contrary to Lagos v. United States, 584 U.S. 577 (2018), by affirming restitution
exceeding $840,000 to public entities and a vendor that suffered no direct,
proximate, or actual pecuniary loss, where the City/County grants were
reimbursable (pre-approved line-items only), contractors were paid, and an
owner 's certification attested project funds were properly used.

4. NATIONAL IMPORTANCE. Whether certiorari is warranted to prevent the
federalization of ordinary project-management and payment-timing
judgments in public-private developments —conduct expressly governed by
contract —thereby chilling redevelopment projects nationwide and undermining
this Court 's recent efforts to curb federal fraud law. See Ciminelli, 598 U.S. at
312-15; Kousisis, 145 S.Ct. 1382 (2025).

Whether the Sixth Circuit's affirmance of wire-fraud convictions conflicts with the Court's requirement of proving knowing and intentional misrepresentation at the time of property obtainment