1. When a government's appeal process is illusory or non-existent to allow a party to challenge a government's total closure of a business resulting in the loss or taking of property, and the government further impedes the process, implicating a Takings Clause claim, whether the illusory appeal process is a per se violation of procedural due process under 42 U.S.C. § 1983 requiring no need to exhaust state remedies before the claim becomes ripe for federal adjudication under this Court's legal principle as explained in Knick v. Twp. of Scott, 588 U.S. 180, 185 (2019) and Patsy v. Board of Regents of State of Fla., 457 U.S. 496 (1982).

2. There is a Circuit split regarding the existence of categorical "police power" exceptions in the context of the Takings Clause of the Fifth Amendment. The Seventh, Eighth, Ninth and Tenth Circuits hold that there are categorical police-power exceptions to the Takings Clause. The Fourth, Sixth and Federal Circuit have held that Supreme Court's jurisprudence recognizes that Government actions taken pursuant to the police power are not per se exempt from the Takings Clause. The question presented is: Whether the Takings Clause of the Fifth Amendment contains a categorical "police power" exception immunizing the government from providing just compensation.

Whether the Takings Clause of the Fifth Amendment contains a categorical police power exception immunizing the government from providing just compensation