In Re Thomas F. Williams

Question one: Whether the federal district & circuit court and the Florida State courts violated the Petitioner’s 6th & 14th Amendment rights—when they failed to apply the plain language in Martinez v. Ryan. 566 U.S. 1, 132 S.Ct. 1309 (3/20/2012); Trevino v. Thaler. 569 U.S. ., 133 S.Ct. 1911 (5/28/2013), and Edwards v. Carpenter. 529 U.S. 446, 120 S.Ct. 1587 (2000) to address the merits of the Petitioner’s ineffective assistance of counsel claims and prosecutor & trial Court issues for procedural default reasons which resulted in a miscarriage of justice? Question two: Whether the Petitioner’s due process and sixth amendment rights were violated when the trial counsel, appellate counsel and the court failed to apply the standards for bias jury members found in Smith v. Phillins. 455 U.S. 209, 102 S.Ct. 940 (1982); Remmer v. U.S.. 350 U.S. 377, 76 S.Ct. 425 (1956); U.S. v. Wood. 299 U.S. 123 (1937)? Question three: Whether the trial judge violated Petitioner’s constitutional rights by enhancing the sentence beyond the signed scoresheet sentence (20 years, App. 19) for all nine charges and by overstepping his authority by disallowing the jury to be involved or to consider the recommended scoresheet causing Petitioner’s right of trial by jury to be denied? Question four: Whether the trial judge violated Petitioner’s rights when he established a rule (R. 91, App. 98-99) that disallowed defense counsel from inquiring the accusers on cross-exam in order to show one of the accusers was the - Page ii of viii -