1. Whether the Petitioner's sentence violated his Sixth Amendment right to
a jury trial when the trial court imposed a minimum mandatory sentence of life
imprisonment based on the trial court's finding that the Petitioner is a prison releasee
reoffender (i.e., the trial court made a factual finding that the Petitioner's offenses were
committed within three years of the date that he was released from prison) – a
conclusion that was not found beyond a reasonable doubt by the jury. Alternatively,
whether Almendarez-Torres v. United States, 523 U.S. 224 (1997), is still good law in
light of the Court's recent Sixth Amendment jurisprudence.

2. Whether the court of appeals in this case improperly applied the
"reasonable jurists could debate" certificate of appealability standard articulated by the
Court in Miller-El v. Cockrell, 537 U.S. 322 (2003).

Whether the Petitioner's sentence violated his Sixth Amendment right to a jury trial