1. Given that the Florida Supreme Court affords a right to appeal to a capital defendant, even in the posture of a successive attempt to seek postconviction relief, does the Due Process Clause of the Fourteenth Amendment require that appeal to be "'more than a 'meaningful ritual,'" Evitts v. Lucey, 469 U.S. 387, 394 (1985) (quoting Douglas v. California, 372 U.S. 353, 358 (1963)), or must it require the Florida Supreme Court to actually engage in meaningful appellate review of Mr. Kearse's constitutional claims and, if so, did the Florida Supreme Court's "review" of Mr. Kearse's claims violate Due Process?
2. Does the Florida Supreme Court's understanding of due diligence—unsupported by any case-specific context and steeped in hindsight—comport with this Court's definition of diligence as explained in Williams v. Taylor, 529 U.S. 420 (2000), and Holland v. Florida, 560 U.S. 631 (2010)?
3. Can a state procedural bar, or a finding of a lack of diligence in bringing a claim of intellectual disability, override the Eighth Amendment prohibition against executing the intellectually disabled?
Whether the Florida Supreme Court's failure to meaningfully engage with a capital defendant's constitutional claims, including intellectual disability claims, violates the Due Process Clause of the Fourteenth Amendment, and whether state procedural bars can override the Eighth Amendment's prohibition on executing the intellectually disabled