1. Whether, in the absence of any statutory post-conviction vehicle to challenge a final criminal forfeiture rendered unlawful by new, substantive Supreme Court precedent that applies retroactively, the common-law writ of audita querela may fill that remedial gap.

2. Whether a court may deny relief based on a failure to challenge forfeiture on direct appeal where the petitioner seeks to apply new, substantive Supreme Court precedent that applies retroactively and was unavailable at the time of the direct appeal.

3. Whether a court of appeals may deny audita querela relief from a final forfeiture rendered unlawful by Supreme Court precedent, based solely on the premise that forfeiture was not challenged on direct appeal, where the appellate record establishes irrefutably that it was, yet the court of appeals refused to adjudicate that fundamental error before summary affirmance.

4. Whether a court of appeals may summarily affirm a judgment where preserved claims of structural constitutional error — specifically judicial bias — remain undefended by the government on the merits and unadjudicated by any court.

5. Whether summary affirmance is permissible where the prosecutor was disqualified and compelled to testify regarding his alleged conflict of interest and misconduct, yet nonetheless continued to control the very proceedings that the Constitution requires be conducted by a disinterested prosecutor.

Whether the common-law writ of audita querela may provide post-conviction relief from a final criminal forfeiture judgment rendered unlawful by new, retroactively applicable Supreme Court precedent where no statutory post-conviction vehicle exists, and whether a court of appeals may summarily affirm the denial of such relief based on failure to challenge forfeiture on direct appeal or without adjudicating preserved claims of structural constitutional error including judicial bias and prosecutorial disqualification