Question I: Whether the Sixth Amendment ' jury-trial guarantee, taken together with the Fourteenth
Amendments ' right to due process require that the legislative silence as to the mental state requirement
for the common law derived/infamous crime of Murder in the First Degree, under Colorado Revised
Statute §18-3-102(1 )(b) (Repealed 2021) must be construed to require a culpable mental state element
component for the conduct, circumstance or result of "a death caused by anyone "?

Question II: Whether the Sixth Amendment 's guarantee of effective assistance of counsel in plea
negotiations places the burden of providing effective assistance on the client by requiring that the client
must advise counsel of viable defenses, develop evidence in the record, and present such defenses and
evidences to both prosecutors and the court?

Whether the Sixth Amendment' jury-trial guarantee, taken together with the Fourteenth Amendments' right to due process require that the legislative silence as to the mental state requirement for the common law derived/infamous crime of Murder in the First Degree, under Colorado Revised Statute §18-3-102(1)(b) (Repealed 2021) must be construed to require a culpable mental state element component for the conduct, circumstance or result of 'a death caused by anyone?