I Did the third Circuit err in misapplication of Strickland and Slack when Brown had made a substantial showing of undisputed factual evidence apparent on the record that his plea was entered involuntarily and counsel was ineffective for providing incorrect advice a decision conflict with it's and other circuit and contrary to clearly established Federal law and 28 U.S.C. § 2254(d)(1) & (2).

II Did the Third Circuit err affirming the denial of Brown's § 2254 petition where the District Court failed to conduct an evidentiary hearing to resolve the factual disputes.

Whether the Third Circuit misapplied Strickland and Slack standards in denying Brown's ineffective assistance of counsel claim when substantial evidence suggested his guilty plea was involuntarily entered