Is counsel ineffective under the Sixth and Fourteenth Amendments when no investigation is conducted pre-trial concerning the client's developmental-delay-issues, very-low-IQ-scores, and history-of-Social-Security-benefits, and post-conviction investigation reveals such relevant information as to the client's state-of-mind in a self-defense case?

QUESTIONS PRESENTED Ohio places the burden of proof and persuasion in a self defense case on the person asserting self defense. A person’s state of mind is relevant in a self defense case. A life long history of developmental delay issues, very low IQ scores and Social Security disability records are relevant to the state of mind issue. I. Is counsel ineffective under the Sixth and Fourteenth Amendments of the federal Constitution when no investigation is conducted pre-trial concerning the client’s developmental delay issues, very low IQ scores and history of Social Security benefits and post conviction investigation reveals such relevant information as to the client’s state of mind in a self defense case? IL. Is counsel ineffective under the Sixth and Fourteenth Amendments of the federal Constitution when one counsel does not know what the average IQ score is and lead counsel testifies it is between 70-80 and counsel does not consult a mental health expert when the affirmative defense of self defense is presented and the client testifies with a recent IQ score in the low 50's? 2 List of Related Cases 1. State Post Conviction II State v. Thomas, 2019 Ohio 4247, Ohio Court of Appeals, case number 29112, 10-16-19 State v. Thomas, Ohio Supreme Court case number 2019-1648, 2-26-20 2. State Post Conviction I State v. Thomas, 2016 Ohio 5507, Ohio Court of Appeals, case number 27698, 8-24-16 State v. Thomas, Ohio Supreme Court case number 2016-1480, 4-19-17 Thomas v. Ohio, U.S. Supreme Court case number 17-5117, cert denied 10-2-17 3. Direct appeal State v. Thomas, 2015 Ohio 2935, Ohio Court of Appeals, case number 27266, 7-22-15 State v. Thomas, Ohio Supreme Court case number 2015-1482, 12-30-15 Thomas v. Ohio, U.S. Supreme Court case number 15-1214, cert denied 5-16-16 3