Keith Charleston v. Jeffrey Woods, Warden
I. PETITIONER'S STATEMENT WAS UNCONSTITUTIONALLY OBTAINED AS HIS INTOXICATION AND LACK OF SLEEP PREVENTED A KNOWING AND INTELLIGENT WAIVER OF HIS MIRANDA RIGHTS, AND THE TRIAL COURT ERRED IN DECLINING TO SUPPRESS HIS STATEMENT
II. PETITIONER'S CONVICTION FOR PREMEDITATED MURDER MUST BE REVERSED WHERE (1) THERE WAS INSUFFICIENT EVIDENCE OF PREMEDITATION AND DELIBERATION; AND, (2) THE PROSECUTION FAILED TO PRESENT SUFFICIENT EVIDENCE TO DISPROVE SELF-DEFENSE BEYOND A REASONABLE DOUBT
III. PETITIONER'S GUARANTEED FEDERAL AND STATE CONSTITUIONAL RIGHTS WERE VIOLATED UNDER THE UNITED STATES CONSTITUTIONS 67 AND 147 AMENDMENTS; THE MICHIGAN CONTITUTION OF 1963, ARTICLE 1 § 17 AND 20, WHEN TRIAL COUSEL WAS INEFFECTIVE FOR (1) FAILING TO DO AN ADEQUATE AND THOROUGH INVESTIGATION; (2) FAILING TO ADDRESS THE ILLIGAL WARRANTLESS ENTRY INTO HIS MOTHER'S HOME TO ARREST PETITIONER ON OUTSTANDING TRAFFIC TICKETS; AND, (3) FAILING TO CHALLENGE THE UNREASONABLE DELAY IN PROVIDING PROBABLE CAUSE HEARING WHERE PETITIONER WAS ARRESTED WITHOUT A WARRANT ON DECEMBER 26, 2012, AND WASN'T ARRAIGNED UNTIL DECEMBER 29, 2012
Whether petitioner's statement was unconstitutionally obtained due to intoxication and lack of sleep preventing a knowing and intelligent Miranda waiver