1. Whether the State's use in a capital sentencing proceeding of rap lyrics composed by a Black defendant to argue to a nearly all-White jury that the Black defendant must be a violent and dangerous person because he wrote the rap lyrics, violates due process, fundamental fairness, and equal protection under the Eighth and Fourteenth Amendments to the U.S. Constitution.

2. Whether the State's introduction of a state-employed and out-of-court expert's serology report and findings at trial, via the testimony of another expert who testified to and relied upon the absent expert's out-of-court statements as a basis of the second expert's own findings, violates the Sixth Amendment to the U.S. Constitution under Smith v. Arizona, 602 U.S. 779 (2024).

Whether the Texas Court of Criminal Appeals erred in admitting racially inflammatory rap lyrics as evidence and in allowing testimonial out-of-court statements from an absent serology expert via a surrogate expert in violation of the Confrontation Clause