I. Whether a state violates the Due Process Clause by abolishing the writ of error
coram nobis and then rigidly applying a post-conviction custody requirement to
permanently bar any judicial review of a conviction that is void ab initio under the
Double Jeopardy Clause of the Fifth Amendment?

II. Whether the Double Jeopardy Clause permits a state to re-litigate an issue of
ultimate fact, a defendant 's criminal intent, that was necessarily determined by a
prior acquittal, merely by alleging new acts that are used to bootstrap the acquitted
conduct as pattern evidence?

Whether a state violates the Due Process Clause by abolishing the writ of error coram nobis and permanently barring judicial review of a void ab initio conviction, and whether the Double Jeopardy Clause permits re-litigation of a defendant's criminal intent after a prior acquittal