Sam Silverberg v. District of Columbia, et al.

Whether the exclusive jurisdiction to shield local tax assessments from constitutional challenges in a federal court to protect state revenues can be extended when the local tax is used to appropriate property rights?

Whether the appellate court reliance on Jenkins and their assertion that federal jurisdiction is barred from all constitutional claims arising from the assessment is conflicting with Hibbs v. Winn, 542 U.S. 88?

Whether the appellate court abused their discretion by refusing to enter an amended complaint without providing “justifying reasons” for the refusal?

Whether the appellate court abused their discretion when the court introduced state claims for relief where the states have exclusive subject matter jurisdiction, that the plaintiff was effectively seeking a refund which contradicts plaintiffs statements in the record that he is not seeking a refund or challenging the assessment?

Whether the practice of this appellate court to dismiss a complaint having a mix of claims where some claims do not have federal subject matter jurisdiction is conflicting with the second circuit where the surviving claims are adjudicated is an abuse of discretion? Dorce v. City of New York, 2 F.4th 81, 82 (2d Cir. 2021)