MARCUS LAROD JACKSON v. THE STATE OF OKLAHOMA

1. The State's evidence was insufficient to prove the violation of the Oklahoma Corrupt Organization Prevention Act;



2. The district court erred when it gave the incorrect instruction pertaining to the range of punishment for all of the counts in violation of the Fourteenth Amendment to the United States Constitution;



3. The district court abused its discretion when it sentenced Mr. Jackson to Counts 5 and 6 in addition to Count 7 because the allegations arose out of the same transaction in violation of Title 21, section 11 of the Oklahoma Statutes;



4. The district court committed error when it erroneously admitted multiple pieces of evidence that were substantially more prejudicial than probative;



5. Multiple instances of hearsay were admitted in violation of the Oklahoma Evidence Code and the Confrontation Clause of the Sixth Amendment to the United States Constitution;



6. The State's evidence was insufficient to prove conspiracy to commit racketeering;



7. The district court abused its discretion when it denied defense counsel's request for the lesser related offense instruction of gang-related activity;



8. Mr. Jackson was denied effective assistance of counsel in violation of the Sixth Amendment of the United States Constitution and Article II, §§ 7 and 20 of the Oklahoma Constitution;



9. Mr. Jackson's sentence is excessive;



10. The accumulation of error in this case deprived Mr. Jackson of due process of law and a reliable sentencing proceeding in violation of the Eighth and Fourteenth Amendments to the United States Constitution and Article II, § 7 and 9 of the Oklahoma Constitution; and



11. This Court should remand Mr. Jackson's case to the district court with instructions to correct his judgment and sentence to reflect the appropriate conviction in Count 2 by an order nunc pro tunc.