Robert R.D. Callioux v. Tim Lang, Secretary, Washington State Department of Corrections, et al.
1. Whether the "independent judgment" required of federal courts under Article III, as reaffirmed in Loper Light Enterprises v. Raimondo, 603 U.S. 369 (2024), renders the deferential standard of review for AEDPA, 28 U.S.C. § 2254(d), unconstitutional.
2. Whether a Certificate of Appealability should issue where trial counsel failed to call a known exculpatory witness whose testimony would have established reasonable doubt, and whether such conduct constituted ineffective assistance of counsel under the Sixth Amendment and Strickland v. Washington?
Whether the deferential standard of review under the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. § 2254(d), is unconstitutional under Article III as interpreted in Loper Light Enterprises v. Raimondo, and whether trial counsel's failure to call a known exculpatory witness constitutes ineffective assistance of counsel under the Sixth Amendment and Strickland v. Washington