Whether the exception to the procedural default
rule of Yates v United States, 354 U.S. 298 (1957)
applies where this Court has held declared a theory of
law invalid and given the invalid theory retroactive
effect on collateral review of judgments, because it falls
within a substantive change of law and not procedural.

Did the Second Circuit err in determining petitioner
did not meet the burden of establishing an exception to
the procedural rule, precluding collateral review of the
verdict after this Court's decisions in Johnson v United
States , 576 U.S. 591 (2015) and United States v. Davis ,
588 U.S. ___ (2019).

Whether Petitioner's § 924 convictions must be set
aside because the general verdict form fails to show
whether those convictions were premised on the
charged Hobbs Act robbery conspiracy, which is not a
valid predicate, or in the perpetration of a robbery,
which would be a valid predicate.

Whether the exception to the procedural default rule of Yates v United States, 354 U.S. 298 (1957) applies