Whether trial counsel rendered ineffective assistance by failing to investigate and present a PTSD expert; whether the prosecutor committed misconduct by falsely arguing that the defendant testified inconsistently with what he told the police; whether the trial court deprived the defendant of his right to present a complete defense by excluding evidence that an accuser subsequently possessed a gun; whether the cumulative effect of the errors denied the defendant due process

QUESTIONS PRESENTED .022-01 CONSTITUTIONAL PROVISIONS INVOLVED .2 THE COURT OF APPEAL CASE FACTS .4 REASONS TO GRANT CERTIORARI .18 I. TRIAL COUNSEL RENDERED INEFFECTIVE ASSISTANCE BY FAILING TO INVESTIGATE AND PRESENT A PTSD EXPERT; AN EVIDENTIARY HEARING WAS REQUIRED .18 II. BECAUSE TORRES NEVER TALKED TO THE POLICE, THE PROSECUTOR COMMITTED MISCONDUCT BY FALSELY AND PREJUDICIALLY ARGUING THAT TORRES TESTIFIED INCONSISTENTLY WITH WHAT HE TOLD THE A. The Prosecutor Referred to All Three Defendants . 0.0 cee eee eee ee LT B. Doyle Error . 0.00. cee eee ee 18 Il. BY EXCLUDING EVIDENCE THAT AN ACCUSER SUBSEQUENTLY POSSESSED A GUN, THE TRIAL COURT DEPRIVED TORRES HIS RIGHT TO il IV. THE CUMULATIVE EFFECT OF THE ERRORS MADE TORRES’ CONVICTION A DENIAL OF DUE