I. Does a state trial court 's failure to give a unanimity instruction
to a jury in a criminal trial raise a debatable valid claim of the
denial of a constitutional right under the Fourteenth Amendment
Due Process Clause (Schad v. Arizona, 501 U.S. 624, 631-633
(1991)), or do such claims involve Sixth Amendment Jury
Unanimity, which had not been extended to the States at the time
of trial. Apodaca v. Oregon, 406 U.S. 404 (1972)?

II. Does a state trial court 's instruction to the jury in a criminal
trial that the jurors need not be unanimous as to which act
resulted in assault likely to result in great bodily injury, coupled
with an instruction on the elements of a different charge, raise a
debatable valid claim of the denial of a constitutional right under
the Fourteenth Amendment Due Process Clause (Schad v.
Arizona, 501 U.S. 624, 631-633 (1991)), or do such claims involve
Sixth Amendment Jury Unanimity, which had not been extended
to the States at the time of trial. Apodaca v. Oregon, 406 U.S. 404
(1972)?

III. Did the Court of Appeal err in denying Petitioner 's request for
a Certificate of Appeal following the District Court 's denial of
Petitioner 's Petition for a Writ of Habeas Corpus from a state
conviction on the grounds that no reasonable jurist would find it
debatable whether a state trial court 's failure to give a required
unanimity instruction to a jury in a criminal trial states a
constitutional right?

IV. Did the Court of Appeal err in denying Petitioner 's request for
a Certificate of Appeal following the District Court 's denial of
Petitioner 's Petition for a Writ of Habeas Corpus from a state
conviction on the grounds that no reasonable jurist would find it
debatable whether defense counsel 's agreement with the trial
court 's erroneous instruction and/or failure to object and/or
request a unanimity instruction did not result in constitutionally
deficient counsel under the Sixth Amendment?

Does a state trial court's failure to give a unanimity instruction to a jury in a criminal trial raise a debatable valid claim of the denial of a constitutional right under the Fourteenth Amendment Due Process Clause?