I.
WAS MILITARY APPELLATE COURT OBLIGATED TO ACCEPT PETITIONER'S LATE INEFFECTIVE
ASSISTANCE OF COUNSEL CLAIM WHERE IT WAS FILED BY APPELLATE COUNSEL WITHOUT A
SHOWING OF GOOD CAUSE WHERE THE MILITARY APPELLATE COURT HAD NOT YET MADE A
FINAL DECISION IN THE CASE?

II.
QUESTION OF CONSTITUTIONAL IMPORTANCE, NAMELY, WHETHER OR NOT CIVILIAN COURTS
MUST REVIEW A MILITARY MEMBER'S CONVICTION FOR AN INEFFECTIVENESS OF COUNSEL
CLAIM EVEN IF NOT RAISED ON DIRECT APPEAL?

III.
WHETHER OR NOT CIVILIAN COURTS MUST REVIEW A MILITARY MEMBER'S CONVICTION IF THE
MILITARY APPELLATE COURT REFUSED TO ACCEPT AND REVIEW AN INEFFECTIVE ASSISTANCE
OF COUNSEL CLAIM ON DIRECT APPEAL OR THE APPEAL WAS LEGALLY INADEQUATE?

IV.
CAN A VIOLATION OF A FULL AND FAIR MILITARY APPEAL BE EXEMPT OF BEING
PROCEDURALLY DEFAULTED AND BE RAISED AT ANY TIME TO A CIVILIAN COURT?

V.
CAN A MILITARY MEMBER RAISE A LACK OF SUBJECT-MATTER JURISDICTION CLAIM AT ANY
TIME AND ANYWHERE TO INCLUDE DURING HABEAS CORPUS PROCEEDINGS, AND IS A CIVILIAN
COURT OBLIGATED TO ACCEPT, REVIEW, AND ADDRESS THE CLAIM EVEN IF NOT ORIGINALLY
RAISED?

VI.
WHETHER TRIAL COUNSEL'S FAILURE TO PRESENT TO THE JURY FACTS WHICH ARE HIGHLY
PROBATIVE OF AN AFFIRMATIVE DEFENSE WHICH IF ACCEPTED BY A JURY WOULD RESULT IN
PETITIONER'S ACQUITTAL, AND WERE UNDISPUTED AND UNCONTROVERTED BY RESPONDENT IN
HABEAS CORPUS PROCEEDINGS, CONSTITUTES A SUFFICIENT SHOWING OF 'ACTUAL
INNOCENCE' TO EXEMPT HIS CLAIMS FROM THE BAR OF PROCEDURAL DEFAULT?

VII.
DOES SUPREME COURT CASE LAW IN MARTINEZ V. RYAN, EVITTS V. LUCEY, MASSARO V.
UNITED STATES, RHEUARK V. SHAW, DOUGLAS V. CALIFORNIA, AND GRIFFIN V. ILLINOIS
ALTER AND/OR CLARIFY SUPREME COURT PRECEDENT IN BURNS V. WILSON AS TO A CIVILIAN
COURT'S LIMITS IN REVIEWING MILITARY CONVICTIONS?

VIII.
IS A MILITARY MEMBER'S INEFFECTIVENESS OF COUNSEL CLAIM EXCEPTED FROM THE
JURISDICTIONAL BAR IN CIVILIAN COURTS AS AN ESSENTIAL JURISDICTIONAL
PREREQUISITE THAT MUST BE REVIEWED EVEN IF NOT RAISED ON MILITARY APPEAL?

IX.
IS A MILITARY APPEAL JUDGMENT VOID AB INITIO WHERE THE ORIGINAL MILITARY OPINION
IS CONDUCTED ILLEGALLY BY WAY OF A CONFIRMED-ILLEGALLY-APPOINTED JUDGE AND THE
SUBSEQUENT DECISION IS CONDUCTED WELL AFTER PETITIONER HAD REQUESTED GRANT OF
REVIEW TO THE COURT OF APPEALS FOR THE ARMED FORCES (CAAF) , AND NO REMAND EXISTS
FROM THE CAAF FOR THE AIR FORCE COURT OF CRIMINAL APPEALS (AFCCA) TO CONDUCT THE

Was military appellate court obligated to accept late ineffective assistance of counsel claim