William Ford v. Mike Parris, Warden
1. WOULD JURIST OF REASON DISAGREE AND FIND DEBATABLE THE CORRECTNESS OF THE SIXTH AND DISTRICT COURTS' FINDING OF EFFECTIVE ASSISTANCE OF COUNSEL WHERE COUNSEL FAILED TO REQUEST AN APPROPRIATE BURDEN OF PROOF INSTRUCTION IN THE CASE-ESPECIALLY WHERE SUCH COURTS RELIED UPON A SUFFICIENCY OF THE EVIDENCE ANALYSIS RELATIVE THE PREJUDICE PRONG?
2. WOULD JURIST OF REASON DISAGREE AND FIND DEBATABLE THE CORRECTNESS OF THE SIXTH AND DISTRICT COURTS' PROCEDURAL DEFAULT RULING RELATIVE INEFFECTIVE ASSISTANCE OF TRIAL COUNSEL-WHERE COUNSEL FAILED TO SUBMIT A PROMISED DEFENSE WITNESS, MISS LAURA SMITH, IN SUPPORT OF THE SELF DEFENSE THEORY PRESENTED BY COUNSEL-AS BEING NON-SUBSTANTIAL TO ESTABLISH CAUSE BASED UPON INEFFECTIVE ASSISTANCE OF POST-CONVICTION COUNSEL FOR FAILURE TO RAISE SUCH INEFFECTIVE ASSISTANCE OF TRIAL COUNSEL CLAIM?
Would jurist of reason disagree and find debatable the correctness of the Sixth and District Courts' finding of effective assistance of counsel