This case presents two important questions concerning
protection of private property rights under the Fifth and
Fourteen Amendments. These questions are:
1. Whether the New Jersey Supreme Court erroneously
distinguished this Court's precedents in Horne v. Dep't of
Agric., 576 U.S. 350 (2015) and Cedar Point Nursery v.
Hassid , 594 U.S. 139 (2021) thereby failing to find that a
per se physical taking of private property occurred where
Petitioner Hospitals are required by statute to provide
access to their hospital facilities and healthcare services to
patients who are unable to pay, are prohibited from billing
those patients for services and treatments provided, but
instead must rely on underfunded and unguaranteed
subsidies?
2. Whether certiorari should be granted to clarify
that Penn Central's ad hoc standard should not be used to
summarily condone government action where, as here, the
New Jersey Supreme Court found, without any reference
to the record, that Petitioners have no reasonable
investment-backed expectations simply because they do
business in a highly regulated industry and that the nature
of the government action was to "adjust the benefits and
burdens of economic life to promote the common good"?

Whether the New Jersey Supreme Court erroneously distinguished precedents regarding physical takings of private property under the Fifth and Fourteenth Amendments