1. Whether the United States Court of Appeals for the Fourth Circuit violated Petitioner's Fifth Amendment right to due process by denying his motion to amend his informal opening brief, thereby foreclosing appellate review of substantial legal and factual issues, in contravention of this Court's holding in Foman v. Davis, 371 U.S. 178 (1962).

2. Whether the Fourth Circuit erred in affirming the district court's grant of summary judgment on Petitioner's Maryland False Claims Act (MFCA) retaliation claim, where state and federal courts interpret the MFCA and federal False Claims Act (FCA), 31 U.S.C. § 3730(h), in pari materia, and whether the decision creates a circuit split by departing from Simmons v. United States, 279 F.2d 345 (4th Cir. 1960), and Murray v. UBS Securities, LLC, 601 U.S. _(2024).

3. Whether the trial court's exclusion of critical evidence and issuance of flawed jury instructions deprived Petitioner of a fair trial under the Due Process Clause, where evidentiary and instructional errors cumulatively undermined Petitioner's statutory protections under the FCA and violated clearly established standards set forth in Sanjour v. EPA, 56 F.3d 85 (D.C. Cir. 1995), and Grant v. United Airlines, Inc., 73 F.4th 138 (4th Cir. 2023).

Whether the Fourth Circuit violated due process by denying a motion to amend an informal opening brief and erred in affirming summary judgment on a False Claims Act retaliation claim