(1) The Conviction and/or Sentence was in violation of the United States Constitution, Mississippi Constitution, and Laws of Mississippi.
(2) The Conviction and/or Sentence as a Habitual by amending indictment The day of Sentencing if in Violation Of Miss. R. Cr. P. 14.1 and Contrary to Supreme Court decisions violating Price V Vincent 533 US 054, 153 L.Ed 2d 873, 193 S.Ct 1848 2523).
(3) Improper indictment- Does not list all elements of Burglary and none of the elements of the Underlying Charge of Larceny F therefore, Not Charging the crime of Burglary violation OF US Const, 5th Amend. and Miss. Const, Art 3, Sec. 37.
(4) Ineffective assistance of Counsel in Violation of US Const, 6th & 14th Amends., Miss. Const, Art. 3 Sec. 37 Strickland V Washington 466 US 668, 80 US V Cranie 539 US 638, & Harding V Davis 378 F.2d 1341, 1345; Con 1989).
(5) There has been an intervening decision of the Supreme Court, Hughes v State 291 So3d 793(2020) which would of adversely affected the outcome of the Sentence in accordance with Miss Code Ann 99-39-5 (AG) and 99-39-8 et Seq.
Whether the conviction and/or sentence was in violation of the United States Constitution, Mississippi Constitution, and Laws of Mississippi