1) Is Petitioner actually innocent in a subsequent prosecution when in the previous prosecution another District Court in another county convicted, pronounced and imposed sentence, and issued a cumulation order to that offense? Does jeopardy attach in the previous prosecution even though the District Court did not issue a formal judgment, but incorporated it in the judgment for another cause?

2) State and Federal Circuit Courts are intractably split on what constitutes "New" in new reliable evidence under Schlup-type claims. Is it newly discovered or newly presented?

3) In order to resolve the frequently recurring issue dealing with neuroscience and evolving standards of decency analysis for the legal categorical class of offenders 18-21 years of age, should offenders receive a mitigation hearing before the imposition of a de facto or de jure life without parole sentence?

4) Should Harmelin v Michigan be overruled in part since it was decided 14 years prior to the first inklings of neuroscience data and today, 30 years later, we have a firmer grasp of brain development to determine culpability for crime?

5) How long should a life with parole sentence be that meaningful rehabilitation is still possible?

Is Petitioner actually innocent in a subsequent prosecution when in the previous prosecution another District Court in another county convicted, pronounced and imposed sentence, and issued a cumulation order to that offense?