Is the undefined, non-specific, ambiguous language used in Ohio's App-R.26(B)(2)(c) that results in arbitrary, inconsistent, and discriminatory enforcement unconstitutionally vague in violation of a defendant's right to Due Process under the Fourteenth Amendment and effective assistance of counsel as a first appeal of right as guaranteed by the Sixth Amendment?

QUESTION(S) PRESENTED i ue : 1. Is the undefined, non-specific, ambiguous language used in Ohio's App-R.26(B)(2)(c) that results in arbitrary, incon: sistent, and discriminatory enforcement unconstitutionally : : vague in violation of a deféndant's right.to Due Process . under the Fourteenth Amendment and effective assistance of ceunsel as a first appeal of right as guaranteed by the : : : -: §&xth Amendment? . i : . a . . 2. Does the persistent misrepresentation of the facts, actual ’ arguments presented, and proper standard of review to be . _. used in a petitioner's actual-innocence claim as a gateway oe to defaulted claims violate their Due Pro€ess rights under : _ the Fourteenth Amendment? : ; : (i)