1. Where a capital defendant objected to his attorney's concession of guilt, does the explicit text of
the Sixth Amendment and longstanding right to
counsel jurisprudence circumvent the Teague bar
and require the application of McCoy to cases on
collateral review?

2. Whether McCoy announced a substantive rule
that should be applied retroactively to criminal defendants who were subjected to conviction without
being afforded their constitutional right to counsel?

3. Whether the Griffith rather than Teague standard
should apply to determine the retroactive application of McCoy, where initial review collateral
claims are not final after direct review?

Where a capital defendant objected to his attorney's concession of guilt, does the explicit text of the Sixth Amendment and longstanding right to counsel jurisprudence circumvent the Teague bar and require the application of McCoy to cases on collateral review?