In Re Ramsey E. Clayter

Whether court-appointed, counsel rendered ineffective assistance under the Sixth Amendment where counsel (a) sought to secure a guilty plea against Petitioner’s interests; (b) refused to pursue discovery and to permit Petitioner to review the Commonwealth’s evidence; (c) failed to participate in critical pretrial proceedings, including the pretrial conference; (d) impeded Petitioner’s attendance and participation at critical stages; (e) failed to seek or obtain a pre-judgment judicial probable-cause determination before Petitioner’s incarceration; (f) failed to cross-examine key witnesses; and (g) failed to obtain and provide arrest or search warrants and supporting affidavits.

Whether a criminal judgment entered before the trial court acquired subject­ matter jurisdiction—because no pre-judgment judicial probable-cause determination was made, is void ab initio and requires vacatur as a matter of law, and If so, does this violate the Fourteenth Amendment to the U.S. Constitution.

Whether confining Petitioner for nearly four years and compelling labor without a valid conviction violates the Thirteenth Amendment’s prohibition on involuntary servitude, which permits such servitude only as a punishment for crime whereof the party shall have been duly convicted.

Whether a person can be guilty of a crime never established.