Whether the Board of Prison Terms Violated Senate Bill 261 for Failing to Apply the Legally Correct Standard of Analysis

QUESTIONS PRESENTED FOR REVIEW 1. Whether the Board of Prison Terms Violated Senate Bill 261 for Failing to Apply the Legally Correct Standard of Analysis; and, in Doing so, Failed to Give the Requirement of ‘Great Weight to the Diminished Culpability of Juveniles as Compared to Adults as a Youth Offender for Release on Parole Mandated by the Bill, in Violation of the Due Process Clauses Protected Under the State and Federal Constitutions, is an Important Constitutional Issue ; Requiring Resolution by This Court to Determine a Matrix Differentiating the Standard of Proof for Unsuitability Between a Juvenile and Adult. 2. Whether the Board of Prison Terms Violated the Administrative Procedures Act (APA) Under California Government Code Section 11340.5 In the Instant Case, in Violation of Equal Protection and Due Process as Guaranteed by the State and Federal Constitution, for Applying ; Criteria not Properly Adopted as a Regulation is a Question of Constitutional Magnitude : Worthy of Resolution by this Highest Court? . 3. Whether the Board Failed to Meet the Minimum Burden of Proof Required in the Rule of ‘Some Evidence’ Under the Provisions Articulated in the Holding of In re Lawrence (2008) 44 Cal.4" 1181 when Balanced Against the Legal Criteria of Intent Legislated in Senate Bill 261. 4. Whether Entitlement of Counsel under Penal Code Section 3041.2 Triggers The . Constitutional Right to Effective Assistance of Counsel Guaranteed by The Sixth Amendment to , the United States Constitution is a Question of Constitutional Magnitude Requiring Resolution by this Court? , ; i