WHERE IT CAN BE SHOWN THATTHE ORDER TO REGISTER AS A SEX OFFENDER IS NOT LIMITED
IN SCOPE TO STAND ON A VALID GUILTY PLEA SUPPORTED BY THE EFFECTIVE ASSISTANCE OF
COUNSEL, DOES THE SEX OFFENDER REGISTRATION ACT VIOLATE A CRIMINAL DEFENDANT'S
SIXTH AMENDMENT RIGHT TO COUNSEL AND FOURTEENTH AMENDMENT RIGHT TO DUE
PROCESS BY CREATING AN IRREBUTTABLE PRESUMPTION, AT NEW CRIMINAL TRIALS, THAT
THE ORDER TO REGISTER AS A SEX OFFENDER IS LIMITED IN SCOPE TO STAND ON A VALID
GUILTY PLEA THAT IS SUPPORTED BY THE EFFECTIVE ASSISTANCE OF COUNSEL?

DOES JUSTICE REQUIRE A DETERMINATION THAT MICHIGAN'S PRE-2018 STATUTE OF
LIMITATIONS BARS RETRIAL OF THIS CASE WHERE THE RECORD MAKES CLEAR THAT THE
ACTUS REUS ELEMENT OF A CRIME WAS NOT ACCUSED BY SPECIFIC FACTS AND WAS NOT
PROVEN BY SPECIFIC FACTS?

Where it can be shown that the order to register as a sex offender is not limited in scope to stand on a valid guilty plea supported by the effective assistance of counsel, does the sex offender registration act violate a criminal defendant's sixth-amendment-right-to-counsel, fourteenth-amendment-right-to-due-process