Whether the lower courts erred in failing to find that Mr. Matias-Martinez's § 2254 habeas application was timely filed, or in the alternate, that he was entitled to equitable tolling of the statutory time limitations set by §2244(D)(1)(A), due to state-imposed impediment or because he is actually innocent?

QUESTIONS PRESENTED FOR REVIEW I. WHETHER THE LOWER COURTS ERRED IN FAILING TO FIND THAT Mr. MATIAS-MARTINEZ'S § 2254 HABEAS APPLICATION WAS TIMELY FILED, OR IN THE ALTERNATE, THAT HE WAS ENTITLED TO EQUITABLE TOLLING OF THE STATUTORY TIME LIMITATIONS SET BY §2244(D) (1) (A), DUE TO STATE-IMPOSED IMPEDIMENT OR BECAUSE HE IS ACTUALLY INNOCENT? Il. WHETHER THIS COURT, FOR THE BETTERMENT AND PROTECTION OF THE CITIZENS OF THESE UNITED STATES, MUST CLARIFY AND MAKE THE RULE ABSOLUTE FOR THE LOWER COURTS AND THE STATES IN REGARDS TO THE PROVISIONS SET FORTH BY THIS COURT IN MARTINEZ V. RYAN, 132 S.CT. 1309 (2012), ALLOWING FOR EQUITABLE TOLLING OF THE. STATUTORY LIMITATIONS SET BY 28 U.S.C. § 2244(D) (1) (A), UNDER SUBSECTION (B) OF THAT STATUTE, WHEN SUCH DEFAULT IS THE RESULT OF INEFFECTIVE ASSISTANCE OF COUNSEL? 2