Whether Texas' application of Tome v. United States violates constitutional due process rights by improperly applying prior consistent statement rules and undermining federal procedural protections

QUESTIONS PRESENTED FOR REVIEW QUESTION #1: Is Texas' application of Tome v.United States unconstitutional, or wrong where (1) Texas found four-point analysis of Tome applicable to the case; (2) Texas claims the error does not violate a constitutional right; whereas (3) ; SCOTUS stated in Tome Prior Consistent Statements are substantive evidence under rule 801; and (4) statutory construction of rule 801(d)(1)(B) increases State J interests in finality and comity at the expense of my federal due process rights? QUESTION #2: Is Texas unconstitutionally increasing their interests in finality and abusing comity at the expense of citizens’ right to due process where (1) SCOTUS found in Trevino v.Thaler that the Constructions and ‘procedural framework in Texas do not afford meaningful review of ineffective counsel claims on direct review; (2) a citizen loses presumption of innocence and many civil rights after direct review; and (3) State's refusal to entertain I.A.C. claims until Habeas review raises the burden of proof for petitioners while decreasing the State's burden? la | 2