1. “Whether the Merit Systems Protection Board (MSPB) violated its statutory jurisdiction and due process obligations by failing to provide Petitioner with adequate notice of her right to challenge the validity of federal employee insurance premium overpayments in federal court, as required by the Due Process Clause and Supreme Court precedent.”
2. “Whether the Federal Circuit erred in affirming MSPB’s dismissal of Petitioner’s claims, thereby foreclosing judicial review of agency actions affecting substantial property interests, contrary to Supreme Court authority and the strong presumption in favor of judicial review of administrative action.”
3. “Whether the Merit Systems Protection Board and the Federal Circuit Court of Appeals erred by refusing to address, or refer to the appropriate forum, Ms. Lucas’s colorable statute of limitations defense to the Office of Personnel Management’s overpayment recovery efforts—despite clear Supreme Court precedent that statutes of limitations serve as jurisdictional bars to untimely government claims—and whether such refusal violates the Board’s and the Court’s obligations to act in accordance with law and afford individuals a meaningful opportunity to assert their rights”
4. “Whether the Merit Systems Protection Board and the Federal Circuit Court of Appeals violated their statutory and constitutional obligations by failing to consider and apply the Board’s own controlling precedent in Arthur I. Martin v. Office of Personnel Management, 97 M.S.P.R. 303 (2004)—which requires recalculation of alleged overpayments subject to a 10-year limitation and reconsideration of waiver requests—when adjudicating Petitioner Cambra L. Lucas’s challenge to OPM’s overpayment recovery efforts, thereby depriving her of the benefit of established Board practice, correct jurisdictional analysis, and a meaningful opportunity to assert her rights, in contravention of the Due Process Clause and Supreme Court authority.”
