Here's the IPAC amicus brief submitted in Smylie. (An identical brief was submitted in Heath). There is quite a lot that is new--or at least that is not in the State's response to the Marion County Public Defender Agency amicus brief. But even I am Blakely'ed out for today, so I'm putting it up, for now, without comment.
[Update: For those who like to cut and paste, the brief is available here in WordPerfect format.]
I also understand that the State is going to (try to) divide its time on Wednesday with IPAC. So now Heath's and Smylie's lawyers have a day to prepare something to say in answer, if the Supreme Court permits the brief to be filed and permits IPAC to argue on Wednesday. It seems to me that it would be terribly unfair to permit either filing of the brief or participation in the argument at this point.