Whether a writ of error coram nobis petition can be barred under the two-prong test of the laches defense that challenges the constitutionality of a criminal conviction unconstitutionally acquired under structural errors deficient advisory-only jury instructions

QUESTION(S) PRESENTED (). TO DETERMINE WHETHER OR NOT A WRIT OF ERROR " CORAM NOBIS PETITION CAN BE BARRED-UNDER THE TWO i PRONG TEST UNDER THE DOCTRINE OF A LACHES ~ DEFENSE THAT CHALLENGES THE CONSTITUTIONALITY OF A CRIMINAL CONVICTION —_ UNCONSTITUTIONALLY ; ACQUIRED UNDER STRUCTURAL ERRORS DEFICIENT _ ADVISORY ONLY JURY INSTRUCTIONS THAT TOLD JURORS THE COURTS INSTRUCTIONS COULD BE DISREGARD AS ‘TO THE PRESUMPTION OF INNOCENCE AND THE STATE'S , BURDEN TO PROVE GUILT BEYOND A REASONABLE _ DOUBT? mo (l). TO DETERMINE WHETHER UNDER THE DOCTRINE OF A LACHES DEFENSE TWO PRONGS TEST OF UNREASONABLE : DELAY AND. PREJUDICE CAN A PETITION FOR WRIT OF _ ERROR CORAM NOBIS CAN BE BARRED BASE ON SPECULATIVE CONCLUSIONS FORMER WITNESSES WHO TESTIFIED MAY NOW BE UNAVAILABLE TO TESTIFY WITHOUT A TRANSCRIPT WILL PREVENT UTILIZATION OF ; THE FORMER TESTIMONY EXCEPTION TO THE HEARSAY RULE FOR RE-PROSECUTE WITHOUT THE COURT HAVING FIRST FOUND PROOF OF UNAVAILABILITY OF THE FORMER : WITNESS WHICH IS A PREREQUISITE UNDER THE EXCEPTION TO THE HEARSAY RULE ? oe (li). TO DETERMINE: WHETHER OR NOT THE PUBLICATION OF SKOK AND JENKINS DECISIONS IN 2000 COULD SERVED TO.HAVE PUT COLLINS TO CHALLENGE HIS 1972 CONVICTION AND HIS FAILURE TO SEEK CORAM NOBIS RELIEF IN 2000 COULD BE BARRED : UNDER THE DOCTRINE OF LACHES ALTHOUGH UNTIL . UNGER WAS DECIDE IN 2012 STATE IMPEDIMENTS LAWS OF WAIVER AND ANY COLLATERAL CHALLENGES TO ADVISORY ONLY JURY : INSTRUCTIONS? ,