1) Whether satisfying the second prong of Georgia v. Rachel, 384 U.S. 780 (1966), for removal under 28 U.S.C. § 1443(1) requires a formal state statute, or whether systemic judicial practices and procedural barriers may constitute an equivalent basis for a firm prediction that federal civil rights cannot be enforced in state court.

2) Whether the application of state doctrines such as litigation privilege and ratification constitutes an "equivalent basis " for removal under the second prong of Georgia v. Rachel, 384 U.S. 780 (1966), where their combined effect precludes the enforcement of federal rights to sue, to challenge fraudulent instruments, and to enforce contract terms.

3) Whether imposing monetary sanctions under 28 U.S.C. § 1447(c) on pro se litigants for invoking § 1443(1) in good faith chills the First Amendment right to petition and violates the Supremacy Clause.

Whether satisfying the second prong of Georgia v. Rachel requires a formal state statute or if systemic judicial practices and procedural barriers may constitute an equivalent basis for predicting federal civil rights cannot be enforced in state court