1. Whether the Due Process Clause of the Fourteenth Amendment permits a state supreme court to forfeit a litigant's rights based on an administrative failure in the court's mandatory electronic filing system — where the court's own secure portal shows a timely "Submitted" filing —followed by a refusal to correct the error upon presentation of the system-generated proof.

2. Whether a state trial court violates procedural due process by imposing the "death penalty" sanction of dismissal for asserted discovery deficiencies where the court and opposing party refused meaningful conferral and the court denied the Petitioner's motion seeking the conference required by the court's own case-structuring and discovery framework, thereby creating a procedural trap and foreclosing compliance.

3. Whether due process is violated where later-issued federal agency determinations (Department of Veterans Affairs / Board of Veterans' Appeals) confirm that critical non-VA community-care medical records were missing due to third-party provider transmission failures under federal community-care obligations —evidence that did not exist during the state discovery period —and the state courts nonetheless treated resulting record gaps as willful "discovery abuse" warranting dismissal.

Whether the Due Process Clause of the Fourteenth Amendment permits a state supreme court to forfeit a litigant's rights based on an administrative failure in the court's mandatory electronic filing system — where the court's own secure portal shows a timely 'Submitted' filing —followed by a refusal to correct the error upon presentation of the system-generated proof