1. Should this Honorable Court reexamine its destruction of evidence standard set out in Arizona v. Youngblood; specifically, a reform to the 'bad faith' requirement, due to significant changes in jurisprudence and society since its inception?
2. Did the State of Texas misapply the Youngblood standard when it found no due process violation or bad faith, despite State testimony that acknowledged the lack of fairness to Petitioner due to spoliation?
3. Because the State of Texas enacted the Michael Morton Act, Tex.Code.Crim.Proc. 39.14, and held that this Act guarantees defendants discovery rights beyond Due Process. Does it violate Due Process if Texas does not enforce or protect these rights when spoliation occurs to evidence not turned over in violation of the Act?
Whether this Court should reexamine the 'bad faith' requirement in Arizona v. Youngblood's destruction of evidence standard, whether Texas misapplied Youngblood by finding no due process violation despite acknowledged spoliation, and whether Texas violates due process by failing to enforce discovery rights under the Michael Morton Act when spoliation occurs