Question One:
Prior iu February iu, 2020, Georgia [Supreme Court] Iiau repeatedly held iliai
although the combined effects of trial counsel's errors should be considered
together as one issue, it remains the case that "[t]his State does not recognize the
cumulative error rule ", [and] 'it do not consider the collective prejudicial effect of
multiple errors by the trial court, or the collective prejudicial effect of trial court
error and ineffective assistance of counsel"; The Question is:
• If a State court overrule all of its prior precedent forbidding courts from
consideration of the cumulative prejudice of multiple errors at trial
which conflicted with /'Strickland v. Washington) , should a State prior
blatant disregard for clearly established federal law be discounted at the
expenses of Petitioner's Federal Due Process, Conflict-free Assistance of
Counsel and Equal Protection guarantees?

question iwo:
• Did the state court violate federal Due Process and Equal Protections
guarantees in dismissing habeas petition as untimely and/or successive,
when evidence is presented during the proceeding that Petitioner acted in
a reasonable arid diligent manner iu uncover the legal grounds upon
which he seeks to rely in an allegedly successive petition?

Question Three:
• Does the state court dismissal of habeas petition as untimely and/or
successive conflicts with this Court's decision in Cuyler v. Sullivan. (1980),
since it ignores that in Cuyler v. Sullivan. 446 U.S. 335 (1980), the Court
established that [t]o show ineffectiveness, a petitioner must demonstrate
that his defense attorney had an actual conflict of interest, and that this
conflict adversely affectied the attorney's performance?

Question rour:
• Did the state court decision to dismiss petition as untimely and/or
successive infringe on Petitioner 's Due Process and Equal Protection
guarantees, and conflict with Strickland v. Washington 466 U.S. 669, 698
(1984), since it blatantly disregarded that in Strickland v. Washington,
the Court held that if defendant shows that counsel's "ERRORS" were so
serious as to deprive him of a fair trial, he is entitled to a reversal of
convictions on ineffectiveness grounds?

Question Five:
The State elected to try Mr. Westmoreland on multiple Felony Murder counts and
Vehicular Homicide for the same victim. Georgia is a proximate cause state, and
in virtually all of it's many homicide statutes, including felony murder and
vehicular homicide, the General Assembly has employed the same or very similar
causation phrasing; The question is:
■ Dues the siaie habeas court decision to dismiss petition us untimely
and/or successive conflicts with Jackson v. Virginia. 443 U.S. 307 (1979),
since it blatantly disregard that in Jackson v. Virginia, this Court held
that relief is available if it is found that upon the record evidence
adduced at trial no rational trier of facts could have found proof of guilt
beyond a reasonable doubt in terms of the substantive elements of the
criminal offense as defined by state law?

Whether a state court's overruling of its prior precedent forbidding consideration of the cumulative prejudice of multiple errors at trial conflicts with federal due process, conflict-free assistance of counsel, and equal protection guarantees