1. Given an expanding circuit, and now state court, split regarding whether,
under Griffin v. California, 380 U.S. 609 (1965) and Carter v. Kentucky, 450
U.S. 288 (1981), jury instructions which omit the "no adverse inference "
language —and do not otherwise cover it— can "cure " a prosecutor 's willful
invitation that the jury draw such a negative inference, should this Court grant
certiorari to both resolve the split, and protect the integrity of this Court 's
holdings in Griffin and Cartefl

2. Because the Alabama courts have now been presented with an opportunity to
address, and remedy, the major due process concerns raised by Justice
Sotomayor in Townes v. Alabama, 139 S.Ct. 18, 20 (2018) (Sotomayor, J.
statement regarding denial of certiorari), should this Court grant certiorari to
vindicate federal due process, equal protection, and fundamental fairness,
particularly in light of the fact that the Alabama Courts have recently granted
relief to appellants who faced far lesser violations of their Sixth Amendment
right against self-incrimination than did Mr. Hammonds?

Whether, under Griffin v. California and Carter v. Kentucky, jury instructions omitting 'no adverse inference' language can cure a prosecutor's willful invitation for the jury to draw negative inferences from a defendant's silence