Whether a state court must give retroactive effect on collateral review to the rule announced in Hall because the Supremacy Clause, as held in Montgomery v. Louisiana, 136 S.Ct. 718 (2016), mandates that a State court cannot deny a prisoner's claim that his sentence is violative of the federal constitution by interpreting a case such as Hall as a mere procedural modification of the substantive holding of Atkins but rather the State court must give effect to Atkins' substantive holding?

Does the Florida Supreme Court's decision in Phillips, denying some capital defendants the retroactive effect of Hall, while having given retroactive effect of Hall to other similarly situated capital defendants, create an unacceptably disparate and unequal death penalty system in violation of the Eighth Amendment?

Does the Florida Supreme Court's decision in Phillips violate the ex post facto clause of the United States Constitution?

Whether a state court must give retroactive effect on collateral review to the rule announced in Hall v. Florida