(l)(a) Whether the Sixth Circuit erred by denying a COA on the merits instead of deciding the
"threshold inquiry" of whether a Petitioner has raised a genuine constitutional question under
the Sixth Amendment, when it claims that trial counsel rendered ineffective assistance by: (a)
not objecting to lack of a jury instruction on "accident" and (b) not informing the jury that the
State had the burden of proving the victim's injury was not caused unintentionally by
"accident"?

(1)(b) Whether to decide an issue of IAC on the merits at the COA stage under 2253(c)(2) relying
on STRICKLAND is misplaced, and also a violation of Miller-El v. Cockrell, 537 U.S. 322 at 336-
337 to decide an appeal without jurisdiction?

(l)(c) Whether a defense of "defense-of-another" may operate in conjunction with a defense
of "accident" to excuse an accused's act provided that the victim's death or serious harm was
the result of the accused's lawful act of self-defense or defense-of-another, as argued in United
States v. Jenkins, 59 MJ. 893 ?

(l)(d) Whether a trial court committed PLAIN ERROR and violated a well-settled due process
principle when Petitioner's testimony establishes that a specific instruction (accident in a
murder trial) is required (even if no requested by counsel), and if it is clear beyond a reasonable
doubt that a rational jury would not have found the defendant guilty had the instruction of
"accident" been given, in conjunction with an instruction on "defense-of-another", and
whether the trial court invaded the province of the jury to determine guilt by failing to give an
"accident" instruction "sua sponte"?

(l)(e) Whether the Sixth Circuit's selective interpretation of the State court's findings of fact
cannot change the fact that Petitioner established a prima facie case of "accident" via her trial
testimony, which shifted the "intermediate-burden" to the prosecution to "disprove" a
defense of "accident"?

(l)(f) Whether a defendant can be convicted of murder after having pled "accident" and
WHETHER the Sixth Circuit erred in denying a COA to review the USDC's denial of habeas relief
being that the State failed to produce sufficient evidence of an essential element of murder,
namely, INTENT, to persuade the jury beyond a reasonable doubt, and WHETHER the Sixth
Circuit's decision is in CONFLICT with the Fifth Circuit's decision in Holloway v. McElroy, 632
F.2d 605 (1980, CA5) ?

(l)(g) Whether the Sixth Circuit is systematically erring by denying a COA on the merits and
failing to explain how courts should square the dictates of Martin at 234 that "the killing will
still be excused if the elements of the defense [accident or defense-of-another] are
satisfactorily established [and when the State fails to disprove such a negative-defense]" with
the uncontested fact that Petitioner testified raising the defense of "accident" and counsel
argued "self-defense" and made a Rule-29-Motion-For-Acquittal, but nevertheless, the jury did
convict defendant of "assault and felony-murder", meaning

Whether the Sixth Circuit erred in denying a Certificate of Appealability (COA) on ineffective assistance of counsel claims related to jury instructions on accident and intent in a murder trial