Terry Alfred Coxe v. Daniel White, Superintendent, Washington State Corrections Center
WHETHER THE LOWER COURTS RULINGS' DIRECTLY CONFLICT WITH THE
HOLDINGS IN (1) McQUIGGIN V. PERKINS; (2) CRONIC V. UNITED STATES, AND (3)
CUYLER V. SULLIVAN IN THAT THE COURTS HAVE TIME BARRED A CLAIM OF
INTERNTIONAL COUNSEL ABANDONMENT, WITHOUT A RULING ON THE MERITS, ON THE
SOLE GROUND THAT THIS PRO SE LITIGANT DISCOVERED THE BASIS OF THE ISSUE TOO
LATE TO AVAIL HIMSELF BY HABEAS CORPUS?
WHETHER THE SIXTH AMENDMENTS MANDATE FOR "ASSISTANCE" BY COUNSEL "FOR THE
DEFENCE" OF THE ACCUSED SPEAKS TO THE COURT'S JURISDICTION TO ENTER A VALID
JUDGMENT, AND WHETHER SUCH "ASSISTANCE' IS SUFFICIENTLY FUNDAMENTAL AND
ESSENTIAL TO SECURING A FAIR TRIAL, THAT A SIGNIFICANT DEPRIVATION OF THIS
RIGHT WOULD CONSTITUTE A UNIQUE TYPE OF HABEAS CLAIM EXEMPT FROM THE AEDPA's
STATUTE OF LIMITATIONS?
WHETHER THE AEDPA's TIME LIMITATION DISPROPORTIONATELY AFFECTS A PROTECTED
CLASS OF INMATES UNABLE TO HIRE POST CONVICTION COUNSEL AND WHETHER ENFORCING
THE LIMITATIONS UPON THE UNDEREDUCATED PRO SE LITIGANT BECAUSE OF HIS COGNITIVE
RESTRICTIONS CONSTITUES AN UNCONSTITUTIONAL SUSPENSION OF THE WRIT OF HABEAS
CORPUS?
WHETHER MR. COXE IS ENTITLED TO EQUITABLE TOLLING ON THE GROUNDS OF HIS
DILIGENT EFFORTS TO ESTABLISH HIS INNOCENCE WITHOUT ACCESS TO THE DISCOVERY,
AND AFTER HAVING BEEN DEFRAUDED FOR HIS LIFE SAVINGS BY A LAWYER WORKING IN
COLLUSION WITH AN OVER-ZEALOUS PROSECUTOR?
Whether the lower courts' rulings directly conflict with the holdings in (1) McQuiggin v. Perkins; (2) Cronic v. United States, and (3) Cuyler v. Sullivan