Did the Court of Appeals err in denying a certificate of appealability over trial counsel's potential ineffectiveness in the plead-vs-trial decision?

QUESTION PRESENTED The lower courts are divided about what a competent criminal defense attorney must do when, as happened here, the prosecution offers a plea bargain. Some courts say that a lawyer need only transmit the offer. Other courts— consistent with the plurality opinion in Von Moltke v. Gillies, 332 U.S. 708 (1948)—hold that trial counsel must not only transmit the offer, but also provide a recommendation about whether the plea offer is a good one. Despite both the split of authority and trial counsel’s own admission that he did not provide a recommendation about the proposed plea agreement, the Fourth Circuit denied a certificate of appealability from the denial of § 2255 relief. Accordingly, the question presented is as follows: 1. Did the Court of Appeals err in denying a certificate of appealability over trial counsel’s potential ineffectiveness in the plead-vs-trial decision? i