Ricardo Mejia Reyes v. Associated Risk Management, Inc.

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1. Whether the Due Process Clause of the Fourteenth Amendment to the United States Constitution is violated when a state workers' compensation insurer, acting under color of state law, denies a claimant's valid claim for work-related injury benefits without providing meaningful notice of the basis for denial, an adequate opportunity to be heard before a neutral decisionmaker, or access to the administrative record upon which the denial was based, and when the state courts affirm such denial under a deferential standard of review that forecloses independent examination of the federal constitutional claim.

2. Whether the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution is violated when a state workers' compensation system, as administered and enforced by the insurer and affirmed by the courts of the State of Nevada, treats injured workers who are members of a protected class differently from similarly situated claimants, by subjecting their claims to heightened scrutiny, requiring additional documentation not required of other claimants, and by denying those claims at a disproportionate rate, without a rational basis sufficient to survive even rational-basis review. Page 9 of 49