Ground One

• Claim: The Texas Constitution, Article I, Section 9 may protect rights beyond what the U.S. Fourth Amendment protects regarding open fields and related protections.

• Relief Sought: Federal habeas relief to address this asserted greater state protection.

Ground Two

• Claim: The holding in Franks v. Delaware should apply to material omissions in a search-warrant affidavit.

• Relief Sought: Federal habeas relief to challenge the validity of the search warrant based on alleged omissions.

Ground Three

• Claim: The search-warrant affiant has an obligation to provide a magistrate with information that seriously undermines the credibility of the affiant’s primary source.

• Relief Sought: Federal habeas relief to remedy credibility-related deficiencies in the warrant affidavit.

Ground Four

• Claim: Ineffective assistance of appellate counsel.

• Relief Sought: Federal habeas relief, potentially including relief tied to appellate-counsel shortcomings (e.g., new grounds or remand for a new appeal).

Ground Five

• Claim: Ineffective assistance of trial counsel.

• Relief Sought: Federal habeas relief addressing trial-counsel shortcomings; may support requests for new proceedings or reconsideration of conviction.

Ground Six

• Claim: Due process violation due to the state relying on false testimony at trial.

• Relief Sought: Federal habeas relief to address alleged false-testimony violations and wrongful conviction.

Ground Seven (Newly discovered evidence / DNA-related)

• Claim: Post-conviction DNA testing would establish innocence; newly discovered evidence undermines the State’s theory.

• Relief Sought: Post-conviction DNA testing of specific items (e.g., handgun barrel, swabs, pillow with bloodstains, blood on gun) and related relief such as reversal/remand for a new trial if DNA results are favorable.