1. Whether courts evaluating ineffective-assis- tance-of-counsel claims may evaluate only each error in isolation—or whether they are obligated to consider the prejudice resulting from the cumulative effect of counsel’s deficiencies.

2. Whether a trial court’s wholesale adoption in a capital case of the State’s proposed order without providing any judicial guidance or substantive change violates the Due Process Clause or Eighth Amend- ment.

1. When a government’s appeal process is illusory or non-existent to allow a party to challenge a gsovernment’s total closure of a business resulting in the loss or taking of property, and the government further impedes the process, implicating a Takings Clause claim, whether the illusory appeal process 1s a per se violation of procedural due process under 42 U.S.C. § 1983 requiring no need to exhaust state remedies before the claim becomes ripe for federal adjudication under this Court’s legal principle as explained in Knick v. Twp. of Scott, 588 U.S. 180, 185 (2019) and Patsy v. Board of Regents of State of Fla., 457 U.S. 496 (1982).

2. There is a Circuit split regarding the existence of categorical “police power” exceptions in the context of the Takings Clause of the Fifth Amendment. The Seventh, Eighth, Ninth and Tenth Circuits hold that there are categorical police-power exceptions to the Takings Clause. The Fourth, Sixth and Federal Circuit have held that Supreme Court’s jurisprudence recognizes that Government actions taken pursuant to the police power are not per se exempt from the Takings Clause. The question presented 1s:

Whether the Takings Clause of the Fifth Amendment contains a categorical “police power” exception immunizing the government from providing just compensation.

. QUESTION(S) PRESENTED

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1. Whether the state court erred in upholding, contrary to U.S. v. Bajakajian, 524 U.S. 321 (1998), and the Excessive Fines Clause, a mandatory fine pursuant to a statute that does not allow any proportionality considerations?

2. Whether the state court erred in affirming, contrary to the holdings of the supreme courts of other states and the Excessive Fines Clause, fines and surcharges imposed under statutes that do not allow consideration of the defendant’s ability to pay?

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Whether a defendant challenging a prior state conviction under the controlled substances definitions must produce actual state court decisions (i.e., show reasonable probability of prosecution) showing non-generic application of a facially overbroad statute—as the Fifth Circuit alone requires—or whether the statutory text suffices to demonstrate overbreadth—as every other circuit holds?

LIST OF PARTIES PURSUANT TO RULE 14.1(b) Petitioner: Quintell Dewayne Gladney Respondent: United States of America 2