Where there exists intra and inter-circuit splits among the federal courts of appeals on a question of exceptional importance concerning "structural error," should the Supreme Court grant a writ of certiorari to resolve the issue of whether the implied bias doctrine constitutes clearly established federal law?

Where the Supreme Court has repeatedly held in a multitude of cases, that "violations of constitutional magnitude can never be de minimis," in the context of juror bias where the defendant on trial had committed a crime previously against the juror, should a determination of bias be predicated on whether or not the crime involved a de minimis loss to the victim/juror?

Whether the implied bias doctrine constitutes clearly established federal law