Did the Michigan State Administrative Agency Wage and Hour Division violate the US Constitution Contract Clause when it used the Michigan P.W.F.B.A statute to relieve Respondent-Employer of his obligations to pay Petitioner-Employee his paid-time-off compensation

QUESTIONS PRESENTED I. Did the Michigan State Administrative Agency Wage and Hour Division ("WHD"), as upheld by the Michigan Supreme Court, violate the US. Constitution Contract Clause,! when it used the Michigan P.W.F.B.A statute? to relieve RespondentEmployer of his obligations to pay PetitionerEmployee his paid-time-off (PTO) compensation of $26,241.63, which Petitioner has already earned and not forfeited according to his PTO agreement with Employer, based on its written policies, while the U.S. Supreme Court?, federal statutes, federal circuit courts, and other states' highest courts held that accrued vacation with pay/ paid time off is compensation like wages once earned, is due and payable at termination, if not paid during employment? II. Did the Michigan State WHD, as upheld by the Michigan Supreme Court, violate Petitioner's rights of due process guaranteed by the U.S. Constitution when it refused to apply its mandatory adjudication standards to the Petitioner's claim, which resulted in non-payment of his already earned and contractually promised PTO compensation of $26,241.68, while adherence to the "proper standards" is a mandatory due process requirement for administrative agencies performing quasi-judicial 'U.S. Const. art. I, § 10 > Michigan Payment of Wages and Fringe Benefits Act 390 of 1978, M.C.L. 408.471 et seq. 3 Massachusetts v. Morash, 490 U.S. 107, 120 8.Ct. 1668, 104 L.Ed.2d 98 (1989) “U.S. Const., amend. XIV ii functions to ensure "fair play,"5 and while following the mandatory adjudication standards would have resulted in requiring pay of such already earned compensation to Petitioner? III. Did the Michigan State WHD Agency, as upheld by the Michigan Supreme Court, violate Petitioner's rights of equal protection guaranteed by the U.S. Constitution,® when it refused to require Respondent-Employer to pay Petitioner his already earned PTO compensation of $26,241.63, while WHD required other employers to pay such compensation to similarly situated claimants? IV. Did the Michigan State WHD Agency's decision based on its application of the Michigan P.W.F.B.A. statute, which denied Petitioner his already earned compensation as upheld by the Michigan Supreme Court, enable theft of earnings of $26,241.63 and tax evasion scheme by which it failed to report such earnings and pay $4,014.96 FICA taxes on them, which resulted in Respondent ICMCF's violations of not only state laws, but also federal laws of Social Security, IRS, and the RICO’ Act? 5 Morgan v. United States, 304 U.S. 1, 22, 58 S.Ct. 773, 778, 82 L. Ed. 1129, 1134 (1938) ° U.S. Const., amend. V, XIV 7 Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. 96