Whether the appellate court committed error by overturning Hibbs v. Winn and holding that constitutional claims arising from assessment bar federal jurisdiction even when not negatively impacting revenue flow

1. Whether the appellate court committed error by overturning Hibbs v. Winn, 542 U.S. 88 (2004) by holding that any constitutional claim arising directly from the assessment bars federal jurisdiction even when the claim does not negatively impact the flow of revenue to the general fund? 2. Whether the appellate court committed error by not finding that the defendant was collaterally estopped from asserting that the test for exclusive jurisdiction of constitutional claims was established in Hibbs, by virtue of their litigation in Colemanv. Dist. of Columbia, 70 F.Supp. 3d 58 (D.D.C. 2014)? 3. Whether the appellate court committed error by deciding the case without first resolving the issue of collateral estoppel, where the district court held that when a constitutional claim does not negatively impact the flow of revenue to the general fund, federal courts have jurisdiction? Coleman v. Dist. of Columbia, 70 F. Supp. 3d 58 (D.D.C. 2014)