I - The lower courts and the respondents claim that the Petitioner's petition is
untimely and should be dismissed as such.

II - The lower courts and the respondents claim that the newly recognized
constitutional right set forth in Miller v. Alabama, 132 S.Ct. 2455 (2012), made
retroactive by Montgomery v. Louisiana, 136 S.Ct. 718 (2016) are inapplicable to the
Petitioner.

Ill - The lower courts and the respondent claim that Petitioner is not entitled to
relief based on his age, violating his 8th Amendment Rights against Cruel and
Unusual Punishment and Equal Protection Rights guaranteed by the 14th
Amendment.

Whether the lower courts erred in dismissing the Petitioner's petition as untimely and in finding that the newly recognized constitutional right set forth in Miller v. Alabama and Montgomery v. Louisiana are inapplicable to the Petitioner, and whether the lower courts erred in denying the Petitioner relief based on his age in violation of his 8th Amendment and 14th Amendment rights