1. Whether denying access to sealed ex parte transcripts, essential for proving
actual innocence through alibi witnesses and third-party perpetrator evidence,
violates due process and the right to present a defense under Schlup v. Delo, 513
U.S. 298 (1995), Holmes v. South Carolina, 547 U.S. 319 (2006), and Richmond
Newspapers, Inc. v. Virginia, 448 U.S. 555 (1980), where circuits diverge on
transcript unsealing in innocence claims.

2. Whether the admission of over thirty minutes of highly prejudicial, minimally
probative adult pornography evidence violated the Fifth Amendment's fair trial
guarantee by inflaming the jury, inconsistent with this Court's recent decision in
Andrew v. White, 604 U.S. (2025), and precedents like Payne v. Tennessee,
501 U.S. 808 (1991), exacerbating circuit splits on prejudicial evidence in habeas
review.

3. Whether the Eleventh Circuit's denial of a certificate of appealability, by
imposing a heightened standard that forecloses review of substantial constitutional
claims in habeas proceedings —including ineffective assistance, due process
violations from sealed transcripts, prejudicial evidence, and sufficiency
challenges —conflicts with this Court's precedents in Miller-El v. Cockrell, 537
U.S. 322 (2003), and Slack v. McDaniel, 529 U.S. 473 (2000), amid emerging
circuit splits on COA thresholds, and whether this denial perpetuates a national
crisis in ensuring uniform constitutional protections in child pornography cases.

4. Whether due process under Jackson v. Virginia, 443 U.S. 307 (1979), mandates
appellate review of preserved sufficiency-of-evidence challenges in child
pornography cases, and whether the Eleventh Circuit's COA denial conflicts with
its own precedent and other circuits' application of Jackson.

Whether denying access to sealed ex parte transcripts violates due process and the right to present a defense, and whether the admission of prejudicial adult pornography evidence violated the Fifth Amendment's fair trial guarantee