1. Whether due process and the Sixth Amendment right to effective assistance of appellate counsel are violated where the state courts deny reopening under Ohio App. R. 26(B) despite a substantial, outcome-determinative claim that the jury instructions authorized conviction for voluntary manslaughter predicated upon elements the jury had already determined were not proven beyond a reasonable doubt, producing an internally irreconcilable verdict.

2. Whether due process is offended and appellate counsel is constitutionally ineffective when the state courts uphold a conviction following pervasive evidentiary errors in a close self-defense case—including speculative law-enforcement "sequence of shots" narration, inference-stacking through non-expert testimony, admission of custodial-jumpsuit videos without a limiting instruction, and exclusion of the decedent's contemporaneous intent text—where those errors bore directly on the core issues and the intermediate court refused to reopen the appeal to address them.

Whether due process and the Sixth Amendment right to effective assistance of appellate counsel are violated where state courts deny reopening despite a substantial, outcome-determinative claim that jury instructions authorized conviction for voluntary manslaughter based on elements the jury determined were not proven beyond a reasonable doubt, and whether due process is offended when state courts uphold a conviction following pervasive evidentiary errors in a self-defense case including improper law-enforcement narration, inference-stacking through non-expert testimony, admission of custodial videos without limiting instruction, and exclusion of the decedent's contemporaneous intent evidence