Does the Constitution require that the accused know the
elements of a crime in order to validly plead guilty?

Is Florida § 893.13 categorically a qualifying predicate under
the Sentencing Guidelines? Cf. Shular v. United States, 139
S.Ct. 2723 (2019) (certiorari granted).

Does appellate counsel's failure to file a petition for
certiorari constitute per se ineffective assistance of
counsel?

What remedy is available for petitioner when court-appointed
attorney failed to file timely petition for writ of certiorari
in defiance of the petitioner's written request that same be done?

Is it a due process right to have counsel present at a parole
revocation hearing?

Did the Eleventh Circuit in Smith erroneously conclude that "[n]o element
of mens rea with respect to the illicit nature of the controlled substance" is
implied by the definition of "controlled substance offense" under §4B1.2(b) of
the Guidelines so that a conviction under Florida's non-generic, strict liability
(PWID) statute may properly be counted as
a predicate for imposition of the harsh CO enhancement?

Did the United States Sentencing Commission exceed its statutory authority
under 28 U.S.C. §994(a) when it defined "controlled substance offense" under
§4B1.2(b) of the United States Sentencing Guidelines to include offenses
lacking a mens rea element?

Does the Constitution require that the accused know the elements of a crime in order to validly plead guilty?