I.
Was Petitioner denied Due Process of Law under
the Fourteenth Amendment and the protections
against self-incrimination under the Fifth Amendment and Miranda by the admission of his custodial statement taken by a police officer who
intentionally and repeatedly ignored Petitioner's
invocation of his right to remain silent under Miranda where the record demonstrates that the impermissible police conduct was a deliberate and a
routine interrogation tactic employed by police officers who were "encouraged" by this Court's holding in Harris v. New York permitting the use of
Miranda violative statements for impeachment
and where the police officer knew that any postinvocation statements would be able to be used to
chill Petitioner's decision as to whether to testify
at his trial, thus calling into question this Court's
belief in Harris that it was only a "speculative possibility that impermissible police conduct will be
encouraged" if Miranda violative statements were
permitted to be used for impeachment?

II.
Was Petitioner denied Due Process of Law when
the trial court permitted the prosecutor to question Petitioner about "what he did not tell the
police" about his alibi defense, even though the
omissions were a result of Petitioner's post-arrest,
post-Miranda invocation of silence and were not
inconsistent with his trial testimony?

Was Petitioner denied Due Process and protections against self-incrimination?