1. Whether the Texas Court of Criminal Appeals ("TCCA")—in refusing to
authorize plenary review of Mr. Burton's unrebutted prima facie case that his
intellectual disability measured by current clinical diagnostic criteria rendered
him ineligible for execution—so contravened the Court's decisions and
directives in Hall v. Florida, Moore I, and Moore II, that this Court's
intervention is required to eliminate "an unacceptable risk that persons with
intellectual disability will be executed" in Texas.

2. Whether the TCCA's dismissal of Mr. Burton's intellectual disability claim
under Article 11.071, Section 5 of the Texas Code of Criminal Procedure "is an
adequate and independent state-law ground for the judgment," Glossip v.
Oklahoma, 144 S. Ct. 691 (2024) (Mem.), even though it was necessarily
dependent on a substantive analysis of federal constitutional law as applied to
Mr. Burton's factual allegations.

Whether the Texas Court of Criminal Appeals' refusal to authorize plenary review of an unrebutted prima facie case of intellectual disability rendered the petitioner ineligible for execution