Whether the Superior Court's denial of Reed's postconviction relief motion under Delaware Superior Court Criminal Rule 61 was an abuse of discretion violating due process and hindering federal habeas relief for meritorious constitutional claims

Whether the Superior Court denial of Reed ’s recently-filed motion for postconviction relief, made pursuant to Delaware Superior Court Criminal Rule 61, was an abuse of discretion denying Reed due process and hindering his pursuit of federal habeas relief of all meritorious constitutional claims given that the procedural bars are inapplicable when presenting a colorable claim under Rules 61 (i)(4)-(5)?1. Whether Due Process and Equal Protection of State and Federal law are violated where Reed ’s sentence for Murder First Degree has not been addressed under newly constructed terms now that Delaware ’s sentencing statute for Murder First Degree, 11 Del. 4209, was deemed unconstitutional?2. Whether Reed ’s mandatory life-without-parole sentence constitutes cruel and unusual punishment where progressive and developing evidence indicates that the mitigating qualities of youth contemplated for those under the age of 18 actually encapsulates 18,19, and 20-year-olds?3. Whether Due Process and Equal Protection of State and Federal law are violated where Reed, an indigent, pro se litigant, was not afforded the assistance of counsel in postconviction proceedings despite clear guidance that “the judge shall appoint counsel for an indigent movant ’s first timely-filed postconviction motion ”?4. Whether Reed suffered ineffective assistance of counsel where counsel failed to explore the implied bias and the court ’s treatment of the Black juror in comparison to similarly-situated White jurors, as contemplated by Batson v. Kentucky ?5. Whether Reed ’s rights were violated by the use of discriminatory voir dire questioning that secured an all-White jury who actually knew the victim ’s friends and his relatives?6. Whether. Reed ’s rights were violated by trial counsel ’s.failure to properly investigate and subpoena two crucial defense witnesses that support his innocence?7.