(1) Is a state appellate court's refusal to allow a
petitioner to file a successive petition for PostConviction Relief on an unmitigated, meritorious claim
an unconstitutional denial of Due Process under the 14th
Amendment?

(2) If PCR counsel is ineffective in presenting the claim
of ineffective assistance of trial counsel, is the
underlying constitutional entitlement to effective
counsel at trial a nullity and lie unenforced?

(3) Do defective jury instructions constitute a material
fact sufficient to preclude Summary Judgement on
Petition for 2.4 Post-Conviction Relief?

(4) Is granting Summary Judgement for the state, a
violation of the Due> Process Clause of the 14th
Amendment, where the record establishes triable claims
that have not been addressed?

Is a state appellate court's refusal to allow a petitioner to file a successive petition for Post-Conviction Relief on an unmitigated, meritorious claim an unconstitutional denial of Due Process under the 14th Amendment?