Whether a state's application of an expert-affidavit requirement to dismiss a claim of extreme medical battery violates the Fourteenth Amendment's Due Process Clause by creating an arbitrary barrier to justice for indigent litigants

1. Whether a state ’s application of an expert-affidavit requirement to dismiss a claim of extreme and obvious medical battery —where a doctor non-consensually destroyed healthy genital tissue with a cryogen —violates the Fourteenth Amendment ’s Due Process Clause by creating an arbitrary and insurmountable barrier to justice for indigent litigants. 2. Whether a state court ’s ruling that deliberate, catastrophic damage to a patient ’s genitals constitutes merely “treatment of the correct organ, the skin ” violates the Equal Protection Clause by trivializing male sexual trauma and bodily integrity in a way that would be legally unthinkable for female patients. 3. Does the Fourteenth Amendment permit a state court to effectively grant hospitals and physicians immunity from battery claims by deeming any outcome, no matter how grievous or non-consensual, as per se compliant with an indefensible “standard of care ” 4. Whether a state, through its judicial and medical actors, violates the Fourteenth Amendment ’s guarantee of due process and equal protection by systematically exploiting a patient ’s sexual humiliation —compelling the exhibition of intimate trauma as a precondition for justice, only to then dismiss that evidence as trivial — thereby inflicting a second, institutionalized injury and denying any meaningful remedy for severe bodily and dignitary harm. 5. Whether a state violates the Seventh Amendment right to a jury trial (as incorporated by the Fourteenth Amendment) by invoking a procedural rule to dismiss a claim of severe frostbite injury —a condition universally recognized as an obvious harm by laypersons —solely because the instrument of injury was wielded by a physician, thereby creating an unconstitutional physician-specific exception to the state ’s own “obvious occurrence ” rule. ii