Jurisdiction and- the-Teague-Standard: 1 .
Does the Court have t*fie power to review a State Collateral Review
Court 's failure to give Retroactive Effect to new substantive rules
of Federal Constitutional Law under the Teague Framework?

2 . Montgomery's-Expansion-Of -Millerls-Standard ;
(A) . Does the Court's logic of Roper, Graham, Miller, Montgomery &-
Adams, which prohibit under the Eighth Amendment mandatory Life Sent-
tences without Parole for Ouvenile Offenders, announce a new substan
tive Constitutional rule that was retroactive on State Collateral
Review even for, de-facto-Life.5entence , basically whether Montgomery
expanded Miller 's holding, and whether any such expansion can be
applied retroactively ?
(B) . What is to be done with cases where a juvenile is sentenced to
life with the possibility of Parole arising only - after an extraordin
arily lengthy term of years that exceed
. cy constituting de facto Life Without Parole?

3. Can Lower Court !s- Circumvent Miller :
(A) . Is it now allowable, after a review of the logic of Roper,
Graham, Miller, Montgomery & Adams, which unavoidably extends not
only to de jure Life Without Parole, but also to de facto ones, for a
Lower Court to Circumvent- Miller by sentencing a juvenile to a term
of years beyond his life span?
(B) . Is N.Y. State's Sentencing of Juveniles as if they were not
children , sentencing them to die - in - prison that exceeds his life
expectancy, defying decency without considering the fact that he is a
child , and making the sentence all that counts , without consideration
of rehabilitation, a circumvention of Miller?

4. Retroactive :
(A). Petitioner has a sentence of 92 yrs-to-Life, did the Bronx
Court err in ruling that the retroactive effect did not apply to Pet
itioner's de facta Life Without Parole (Functional Equivalent of
L.W.P.), who will die in prison, has been in prison for 33 yrs since
he was 17 yrs old, has more time in prison than he was alive in free
society, with 60 yrs to go, is. now 50 yrs old with diabetes, also .
short life expectency, who was denied even a hearing?
(B). Whether the cruel & unusual clause in the N.Y.S. Constitution,
as in the U.S. Constitution, is also violated when Petitioner was
sentenced to 92.yfs to Life and he was a juvenile at the time of
crime ... where Bronx Dudge never once mentioned Petitioner's YOUTH
when he sentenced teenage defendant to die in prison under abuse of.
discretionary powers...? .

Increase inthe - Minimum-Activates-Due-Process Clauses : 5.
Here the Petitioner has been sentenced to 92 yrs to Life as a
teenager, does the due process of U.5. Constitution, or N.Y.S. Const
itution, require that a factual-determination , authorizing an increa~
bb-1p. the.Minimum--Part of

Does the Court have the power to review a State Collateral Review Court's failure to give Retroactive Effect to new substantive rules of Federal Constitutional Law under the Teague Framework?