Whether the District Court abused its discretion in denying Mr. Mills' Motion for Relief from Judgment pursuant to Federal Rule of Civil Procedure 60, where newly discovered evidence establishes that the District Attorney made false statements at trial and the State made false representations throughout Mr. Mills' appeals and postconviction proceedings regarding whether the State offered anything to its star witness, JoAnn Mills, in exchange for her testimony, and where such false statements and representations were material to critical decisions made by the district court and prevented Mr. Mills from receiving merits review of his Brady claim.

Whether a defendant's due process rights are violated when the prosecution makes materially false statements about a key witness's plea agreement during a capital trial and subsequent proceedings, thereby preventing merits review of the defendant's claims