1. Federal Antitrust and Due Process Protections

Whether a physician who suffers network exclusion, contract loss, and practice-sale interference after exposing an unlawful Medi-Cal, kickback and market domination scheme may seek federal relief under continuing-violation and concealment doctrines that toll the statute of limitations for those claims.

2. Anti-SLAPP and State Court Procedure

Whether the Ninth Circuit erred in applying California's anti-SLAPP statute, Cal. Code Civ. Proc. § 425.16, to strike all state-law claims without conducting the claim by claim analysis required by Baral v. Schnitt, 1 Cal. 5th 376 (2016), and Bonni v. St. Joseph Health System, 11 Cal. 5th 995 (2021), thereby extending anti-SLAPP protection to non-petitioning conduct.

3. Immunity and Jurisdictional Dismissal

Whether the Ninth Circuit misapplied Mishler v. Clift, 191 F.3d 998 (9th Cir. 1999), by extending absolute quasi-judicial immunity to Medical Board members for ministerial acts—false communications to insurers made long after proceedings ended—and erred in ordering dismissal with prejudice of state-law contract claims barred by the Eleventh Amendment, contrary to Freeman v. Oakland Unified School District, 179 F.3d 846 (9th Cir. 1999)

Whether a physician who suffers network exclusion and practice interference after exposing an unlawful kickback scheme may seek federal antitrust relief under continuing-violation and fraudulent-concealment doctrines that toll the statute of limitations, and whether the Ninth Circuit erred in applying California's anti-SLAPP statute to strike all state-law claims without claim-by-claim analysis and in extending absolute quasi-judicial immunity to ministerial acts outside judicial proceedings