1. Can a state prisoner be incarcerated forever based upon
falsehoods deliberately created to prejudicially bias
future decision makers in the exercise of discretionary
authority when determining the prisoner's suitability
for release after the mandatory portion of his sentence
has been completed?

2. When it is well-established that it violates the Due
Process Clause of the 14th Amendment when a state
prosecutor deliberately creates false evidence or
suborns perjury then knowingly offers it into evidence
at trial to get a conviction; does it also violate the
Due Process Clause when a state prosecutor does the
same thing after conviction and sentence in his
confidential report to state criminal justice officials
in order to prejudicially bias future decision makers
in the exercise of discretion in the parole process?

3. When state statutory law mandates that the trial judge
and prosecutor "shall furnish a summarized statement
of the facts proved at the trial together with a
recommendation for or against commutation, or
parole;" does it violate the Due Process Clause of the
14th Amendment when a prosecutor substitutes falsehoods
directly contradicted by evidence and testimony
presented by the state at trial for the actual facts
proved at that same trial?

4. In the context of a parole hearing where no constitutional
right to parole exists, the overriding concern in
determining a claimed Due Process violation of a state-
created liberty interest is minimizing the risk of error
by allowing parole officials wide lattitude consistent
with their discretionary authority when making parole
decisions. Does this overriding concern require federal
courts to dismiss habeas corpus petitions based on the
claim that known falsehoods were deliberately created by
a state prosecutor and conveyed to state criminal justice
officials as facts of the offense in order to deliberately
mislead parole board members to a prejudicial bias against
favorable exercise of their discretion while considering
the offender for release?

5. Does evidence and testimony presented at trial by the
state meet the standard of "clear and convincing evidence"
that is necessary to establish that inaccurate facts
reported after conviction and sentence are actually
falsehoods that need to be corrected?

6. If a state's highest court has established that prisoners
have a due process expectation to accurate parole records
and that the state parole board must investigate and
correct any substantive inaccuracies when there is clear
and convincing evidence that their information is
substantively false; does the state parole board divest
itself of jurisdiction over the remaining discretionary
portion of a sentence by refusing to vindicate the
prisoner's constitutional Due Process right and
continuing to use false information, demonstrated to
actually be false by clear and convincing evidence
when exercising their discretion?

7. Once a state prisoner discovers that his trial judge and
prosecutor did not provide an accurate summary of the
facts proved at trial to state criminal justice officials
as they were required to do by mandatory state law, and
that prisoner fails to convince those state criminal
justice officials to investigate and correct those
inaccuracies as they were required to do by mandatory
state law; what is the next step that prisoners need to
take in order to vindicate the abuse of his constitutional
Due Process rights? Is that prisoner obligated to begin
his legal quest for vindication in the court wherein the
facts were originally presented under his original

Can a state prisoner be incarcerated forever based on falsehoods to prejudice parole decisions?