I. Has the Constitutional right to due process of law been violated where a prosecutor withholds prison medical records that substantiate a capital defendant's claims of prison assaults and his later diagnosis of PTSD, and then impeaches his mitigation expert and argues for the death penalty claiming that no medical records support the defendant's claimed assaults ?

II. Does counsel render ineffective assistance of counsel in failing to inquire into racial bias in a racially charged capital trial?

Has the Constitutional right to due process of law been violated where a prosecutor withholds prison medical records that substantiate a capital defendant's claims of prison assaults and his later diagnosis of PTSD, and then impeaches his mitigation expert and argues for the death penalty claiming that no medical records support the defendant's claimed assaults?