Whether the government's expert's after-the-fact opinion of the applicable standard of care of Florida Pharmacists is an ex post facto interpretation of the criminal standard of conduct resulting in an unconstitutional conviction based on an ex post facto law

QUESTIONS PRESENTED FOR REVIEW Petitioner Emmanuel I. Mekowulu was a licensed Florida pharmacist who was convicted of conspiracy to knowingly distribute controlled substances (oxycodone) not in the usual course of professional practice. At trial, the government introduced the testimony of an expert witness in the field of pharmacy who testified as to his opinion of “red flags” that would cause a pharmacist to question whether a prescription was issued for a legitimate medical purpose. The questions presented in this Petition are: 1. Whether the government’s expert’s afterthe-fact opinion of the applicable standard of care of Florida Pharmacists is an ex post facto interpretation of the criminal standard of conduct resulting in an unconstitutional conviction based on an ex post facto law. 2. Whether the government’s expert’s afterthe-fact opinion rendered the standard of criminal conduct unconstitutionally vague. 3. Whether in this § 2255 Motion Petitioner is barred by the doctrine of procedural default for failure to raise these issues on direct appeal. i