1. Whether the Arkansas Supreme Court violated due process by affirming
Keesee's capital-murder conviction based on a nonjurisdictional argument
that was never by the State at either the trial level or on direct appeal.

2. And, whether Arkansas Supreme Court violated due process and separation
of powers by refusing to construe Keesee's sufficiency-of-the-evidence and
other arguments related to Arkansas's felony-delivery-murder statute, an
issue of first impression in Arkansas.

Whether the Arkansas Supreme Court violated due process