Whether trial counsel provided ineffective assistance by conceding guilt instead of presenting an insanity defense and whether due process was violated by barring psychiatric and medical evidence to rebut specific intent

I. Almeida received Ineffective Assistance of Counsel as a result of his trial counsel's strategy of conceding guilt to lesser included offenses instead of presenting the only viable defense, “not guilty by reason of insanity. ” II. Almeida was denied due process of law as a result of the Florida Supreme Court precedent which barred his use of psychiatric evidence of mental disease or defect and medical evidence of traumatic brain injury to rebut an element of each chaiged offense that is, specific intent or mens rea and as a corollary his trial counsel was ineffective for failing to preserve this issue for direct appeal by proffering a defense of lack of specific intent or mens rea resulting from his mental condition and traumatic brain injury.