Whether the Court should address the Circuit Split regarding whether, and under what circumstances, a movant's procedural default can be excused because his constitutional vagueness challenge was 'not reasonably available' prior to United States v. Davis, 139 S. Ct. 2319 (2019)

QUESTION(S) PRESENTED Ln this cvveal episode of oul _surisprudence history that wit! dictate the path fo follow ater the famipica tional “ffects anol cnapact caused accross the nahon by Yhr's Courts dlecision: in Cite Stopes vDavis, 139 8. Ct, 23/9 €20/9), Lab boner respeotpully presents the following gmeshons that, Gf Considered por review, will not only fesolve & clivislen Among appeal CIV CIES but also give clarity of tue standaral analysis on general vtreliets, and most impor tentls prevent a monumental MISCAMIOgE of jvsHcei Whether the Court shovlo pud anced fo rhe Cirwit Split regarding whether, and under what CIVCUMS#FANCES, B movant 5 proceolural degault aq be excused because bys consditutonal vagueness challenge was “nor reasonably avalagle" prior to United . Slates y. Davis, /39 9. C¢. 23/9 C20/9), Air Qi. Whether oma gereral veroliet a Section 9249C0) conviction Can oy cannot sano when 13 6ased 07 a jury instruction they allowed the Jw rely upon two | predicates -~ one under the valicl "elements clause" and tle other under the later invalidated as unconstitutionally vague vesidual clause''when the courts find them “inextricably intertwined.” 2.6. Whether a lower covrt rulingthat a jury instruction allowed a jury $o find a ales en dant guildy oF his Section 924 Ce) Off mse based on | his coclegendont conduct in furtherance of “Consprracy Lo Commi Zé hostage toKing and Conspiracy Yo commyst Cay jacking ‘. violates Chis Court's olecisien in Unjteol fates v. Davis, /349 3. Ck. 23/9 C2019): * Petitioner is a fay man of the low yp ensKilled in Pte Laws and, Pherepore, aSks Mhe Court Yo Constrve the presesated questions and this entre pebtion “berally . Haines vs Kearney) 404 U.S. 5/7 C197Z), | | iti : . |