1. Whether the United States Department of
Agriculture's ("USDA") policy, codified within
USDA's Discrimination Financial Assistance
Program ("DFAP "), that excludes applications for
financi al assistance submi tted on behalf of the
estates of deceased farmers for past USDA
discrimination in farm lending programs ("Legacy
claims"), violates Secti on 22007 of the Inflation
Reducti on Act of 2022, Pub. L. No. 117-169
(herei nafter "Secti on 2200 7, and IRA for "Inflation
Reducti on Act").

2. Whether the USDA policy of excluding Legacy
Claims from DFAP violates the Administrati ve
Procedure Act.

3. Whether the USDA policy of excluding Legacy
Claims from DFAP violates 42 U.S.C. §§1981 or 1982.

4. Whether the USDA policy of excluding Legacy
Claims from DFAP violates the Due Process Clause
of the U nited States Consti tution.

5. Whether the Circuit Court's analysis of
USDA's DFAP policy of excluding Legacy Claims
complied with Court's duty under Article III of the
United States Consti tution to exerci se independent
judgment as explained in Loper Light Enterpri ses,
et al. v. Raimando , 603 U.S. ___ 2024 144 S. Ct. 2244
(2024), to determi ne if USDA acted within its
authori ty under §22007.

Whether the Department of Agriculture violated the Administrative Procedure Act and Equal Protection Clause by rescinding the Pigford consent decree and denying loan forgiveness to Black farmers based on race-conscious relief programs