I. Whether this Court should resolve the question left open in Brumfield v. Cain, 576 U.S. 305, 312 (2015): Where a state court refused funds for a mental health expert to demonstrate prejudice from counsel's deficient failure to investigate a defendant's mental illness, which supported partial defenses to the murder charge or mitigated punishment under settled state law, and where a state court refused to hold a hearing on ineffective assistance of counsel, is the state court's denial of a petitioner's ineffective assistance claim an unreasonable determination of facts per 28 U.S.C. § 2254(d)(2) or an unreasonable determination of settled constitutional due process law per § 2254(d)(1) and Ford v. Wainwright, 477 U.S. 399 (1986)?

II. Whether this Court should resolve the disputes among the lower courts about the interpretation of Brumfield, 576 U.S. 305 as to when a state court's refusal of funds for a mental health expert and refusal to hold a hearing on ineffective assistance of counsel results in an unreasonable determination of facts per 28 U.S.C. § 2254(d)(2), as held in Brumfield, 576 U.S. at 317-322 and the Eleventh Circuit's decision in Smith v. Campbell, 620 Fed.Appx. 734 (11th Cir. 2015); see King v. Emmons, 144 S.Ct. 2501, 2504 (2024) (Jackson, Sotomayor, JJ., dissenting from denial of certiorari)? Or, contrarily, where the state appoints deficient trial counsel who fails to obtain an expert and investigate mental illness, and where state appellate courts refuse to order appointment of an expert or

Whether a state court's denial of funds for a mental health expert and refusal to hold a hearing on ineffective assistance of counsel constitutes an unreasonable determination of facts or constitutional due process under 28 U.S.C. § 2254