Whether McGirt v. Oklahoma applies retroactively to final convictions

QUESTIONS PRESENTED 1. Whether McGirt v. Oklahoma, 140 S.Ct. 2452 (2020), applies retroactively to , convictions that were final when McGirt was announced?! 2. Is Oklahoma’s decision in Matloff v. Wallace contrary to clearly established Supreme Court law which holds that subject-matter jurisdiction claims can be raised at any time? . 3. Does Oklahoma’s decision in Matloff v. Wallace serve as an unconstitutional state procedural bar to Petitioner’s jurisdictional challenge under McGirt v. _ Oklahoma? ' In support of this question, Petitioner fully incorporates the arguments presented in the Petition for a ; Writ of Certiorari in Clifton Merrill Parish v. The State of Oklahoma, attached hereto as Exhibit“ “. In addition to the reasons presented in the Petition for a Writ of Certiorari in the case of Clifton Merrill Parish v. The state of Oklahoma, Petitioner further argues that the rule announced in McGirt is more substantial in this case because Petitioner was a juvenile when the crimes were committed. Hence if his case were prosecuted in the court of proper jurisdiction, he would have the benefit of Miller v. Alabama, 507 U.S. 460, (2012) and a more compassionate juvenile justice system.