1. Whether the Court of Appeals violated its constitutional duty by failing to determine
the absence of federal subject-matter jurisdiction after the government omitted its
opposition brief and instead filed a motion for summary disposition in Case Nos. 23-1405,
23-1706, and 23-1520, while simultaneously arguing that the District Court possessed
federal jurisdiction because Puerto Rico is "a current territory of the United States."

2. Whether the repeated failure of the lower courts to address the jurisdictional
challenge — despite clear constitutional and statutory mandates — constitutues an
abuse of judicial power warranting the issuance of a writ of mandamus.

Whether the Court of Appeals violated its constitutional duty by failing to determine the absence of federal subject-matter jurisdiction and whether the repeated failure of lower courts to address the jurisdictional challenge constitutes an abuse of judicial power