The Eleventh Circuit Court of Appeals denied Mr. Salemi a certificate of appealability with a summary order using boiler plate language. Did the Eleventh Circuit Court of Appeals abuse its discretion by not providing a reasoned opinion to support its order? Wilson v. Sellers, U.S. (Jan.2018).

Mr. Salemi's 28 U.S.C. § 2255 claims comprised allegations of out of court, off-record advice from counsel. Section 2255(b) provides the district court shall conduct an evidentiary hearing unless the allegations are conclusively refuted by the record. The out-of-court events were never addressed on the record.

Should the district court have conducted an evidentiary hearing? See Machibroda v. United States, 368 U.S. 487 (1962).

Did the Eleventh Circuit Court of Appeals abuse its discretion by not providing a reasoned opinion to support its order?