1. Whether the state court erred in upholding, contrary to U.S. v. Bajakajian, 524 U.S. 321 (1998), and the Excessive Fines Clause, a mandatory fine pursuant to a statute that does not allow any proportionality considerations?

2. Whether the state court erred in affirming, contrary to the holdings of the supreme courts of other states and the Excessive Fines Clause, fines and surcharges imposed under statutes that do not allow consideration of the defendant's ability to pay?

Whether the state court erred in upholding mandatory fines pursuant to statutes that do not allow proportionality considerations or consideration of the defendant's ability to pay, in violation of the Excessive Fines Clause as interpreted in U.S. v. Bajakajian