Congress through federal legislation created the National Practitioner Data Bank (NPDB) which is overseen by the Health and Human Services (HHS). HHS-NPDB has authority over a board of medical examiner's that takes an adverse action and a State Licensing and certification authorities (Texas Medical Board) under Title IV, Section 1928, Section 1128E, 42 U.S.C. §1, 42 U.S.C. §12 and 42 U.S.C. §l(a)(l)(D). The Questions presented that has National Importance are:

1. Whether Congress, through the creation of the HHS-NPDB, Abrogates sovereign, state and qualified immunity of the Texas Medical Board?

2. Whether Congress creates a Structural Waiver of the Texas Medical Board's sovereign, state and qualified immunity to HHS-NPDB as dictated by the Supremacy Clause in Article VI of the Constitution?

3. Whether Defendants provided Caruso with "Adequate Notice", "Meaningful Hearing" and Due Process of Law before she was disciplined?

4. Whether Defendants deprived Caruso of Liberty to practice in her chosen profession without due process of law?

5. Whether a property interest existed on March 4, 2022 when Caruso was granted a license, and then placing restrictions on that license?

Whether the Texas Medical Board's actions in denying and restricting Dr. Caruso's medical license violated her due process rights under the Fourteenth Amendment