1. Bivens / Fourth Amendment: Whether, after Egbert v. Boule, 596 U.S. 482 (2022), a Bivens remedy remains available for warrantless searches and seizures of property by federal officers (including in joint task-force operations) when alternative remedies are discretionary or inadequate.

2. Qualified Immunity: Whether qualified immunity applies where binding circuit law clearly established the relevant Fourth Amendment constraints, including limitations on warrant scope and warrantless property seizures later in the day following a morning search. See, e.g., Messerschmidt v. Millender, 565 U.S. 535 (2012).

3. Westfall Act and Private/State Co-Conspirators: Whether the Westfall Act, 28 U.S.C. § 2679, forecloses civil RICO liability or other federal claims against private parties and state officials alleged to have conspired with federal agents in joint operations, where the gravamen is fabrication, pretext, or misuse of processes. See Holmes v. SIPC, 503 U.S. 258 (1992); cf. DeGuelle v. Camilli, 724 F.3d 933 (7th Cir. 2013).

4. "New Context" Analysis: Whether the Sixth Circuit misapplied Egbert's "new context" framework by focusing on the defendants' titles (e.g., DEA Diversion Investigator) rather than the core Fourth Amendment violation, contrary to the emphasis on the nature of the constitutional claim. See Hernandez v. Mesa, 140 S. Ct. 735 (2020).

5. Forfeiture / Due Process (Equitable Sharing): Whether seizures executed through the Equitable Sharing regime comport with due process and excessiveness limits when property is taken without timely post-deprivation process and when private entities benefit from the seizure program. See Timbs v. Indiana, 586 U.S. (2019); United States v. Bajakajian, 524 U.S. 321 (1998).

6. Applicant anticipates also addressing whether executive-branch policy (including Executive Order 14119 (May 9, 2025)) bears on the legality of alleged regulatory weaponization in joint state-federal operations, and whether the Sixth Circuit's approach deepens disagreements among the circuits regarding Bivens for warrantless property searches and the adequacy of purported alternative remedies.

7. Constitutional Claims
a. Whether, after Egbert v. Boule, 596 U.S. 482 (2022), a Bivens remedy exists for Fourth Amendment violations involving warrantless property seizures by federal officers.
b. Whether qualified immunity applies to state actors who violate clearly established law while executing federally funded programs.

8. RICO Claims
a. Whether a private corporation (Blue Cross Blue Shield of Michigan) and state officials may be held liable under RICO (18 U.S.C. § 1962(d)) for conspiring to misuse federal funds (Medicare/Medicaid, Equitable Sharing Program) to destroy a business.
b. Whether the Sixth Circuit erred in requiring a "separate criminal purpose" beyond the alleged racketeering activity.

9. Federal Funding Violations
a. Whether recipients of federal funds (Medicare, Medicaid, BJA grants) forfeit immunity for civil rights violations that render their funding impermissible under:
i.

Whether a Bivens remedy remains available for warrantless searches and seizures of property by federal officers in joint task-force operations when alternative remedies are discretionary or inadequate