Whether the United States District Court decision that Mr. Haley cannot establish cause to excuse the procedural default of his substantial claims of ineffective assistance of trial counsel

QUESTION PRESENTED | . NONCAPITAL CASE 1. Mr. Haley, acting pro:se, filed an appeal to the United States Court of Appeals for the Sixth Circuit, therefore, appealing the order United States District Court's, for the Western District of Tennessee Western Division, dismissing his 28 U.S.C. § 2254 Writ of Habeas Corpus Petition (“§ 2254 Petition”), raising the issue for appellate review “Whether the United States District Court decision that “Mr. Haley cannot establish cause to excuse the procedural default of his substantial claims of ineffective assistance of trial counsel raised in his § 2254 petition by showing that he received ineffective assistance of post-conviction counsel based on his post-conviction counsel's failure to raise of all of his substantial claims of ineffective assistance of trial counsel on appeal from his postconviction evidentiary hearing to the Tennessee Court of Criminal Appeals (“TCCA”), especially since T ennessee post-conviction proceedings presented Mr. Haley the first opportunity to raise his substantial claims of ineffective assistance of trial counsel”, was rendered contrary to the Court of Appeals ruling in Sutton v. Carpenter, 745 F.3d 787, 795-96 (6" Cir. 2014) (citing Trevino v. Thaler, 569 U.S. 413 (2013))?” The Court of Appeals refused to grant Mr. Haley's application for a certificate of appealability, finding that because “jurists of reason would not find it debatable whether the district court was correct in its procedural ruling.” This Honorable Court in 2013 in Trevino v. Thaler, 569 US. 413 (2013) reillustrating its ruling in Martinez v. Ryan, 566 U.S. 1 (2012), that ineffective assistance of post-conviction counsel in the very circumstance presented by Mr. Haley's case could establish cause for the default of a claim of ineffective assistance of trial counsel. These circumstances present the following question: Whether this Honorable Court should grant certiorari, vacate the Court of Appeal's order, and remand to the Court of Appeals for consideration of Mr. Haley's argument under Martinez v. Ryan? i 5 , 4