1. Whether a state court's refusal to adjudicate a Rule 60(b) motion on the merits, based on procedural grounds, violates due process where the motion alleges fraud on the court?

2. Whether judgments may be vacated where newly discovered evidence and judicial records demonstrate that material claims were never adjudicated on the merits and involved parties were never properly before the court?

3. Whether reliance on discredited evidence—previously rejected as lacking competent support—can form the basis of a later judgment without violating due process and principles of fundamental fairness?

4. Whether the application of res judicata to bar claims by or against parties not included in prior litigation constitutes a constitutional violation where no full and fair opportunity to be heard was provided?

5. Whether ongoing fraud on the court and denial of access to adjudication on the merits justifies vacatur under Rule 60(b)(3) and warrants this Court's intervention under Rule 22?

Whether a state court's procedural bar to Rule 60(b) motions alleging fraud on the court violates constitutional due process principles