Whether respondent waived/forfeited any of its procedural defenses

QUESTION(S) PRESENTED . { ‘ WHETHER RESPONDENT WAIVED/FORFEITED ANY OF IT’S PROCEDURAL : DEFENSES IN McGIRT’S DECISION AND RESPONDENT IS PROCEDURALLY : BARRED FROM ASSERTING ANY IF IT’S PREVIOUS PROCEDURAL DEFENSES : THAT WERE AVAILABLE AGAINST PETITIONER’S SUBJECT MATTER : JURISDICTION CLAIM IN COLLATERAL POST CONVICTION PROCEEDINGS i WHEN CONVICTON WAS FINAL? WHETHER McGIRT V. OKLAHOMA ANNOUNCED A NEW. VINDICATIVE REPLACEMENT OF SUBSTANTIVE RULE DICTATED BY PRIOR PRECEDENT MADE RETROACTIVE BY TEAGUE’S EXCEPTION TO NON-RETROACTIVITY? : WHICH RESPONDENT REFUSED TO APPLY RETROACTIVELY AS STATE : POSTCONVICTION RELIEF TO CASES FINAL WHEN McGIRT WAS DECIDED ON i JULY 09, 20207 WHETHER LACK OF TRIBES VOLUNTARY CONSENT TO STATE’S ASSUMPTION OF CRIMINAL JURISDICTION AND THE ATEMPTED EXERCISE OF JUDICIAL POWER BY RESPONDENT WITHOUT TRIBE’S CONSENT IS VOID? ii