Was trial counsel constitutionally ineffective for failing to consult or hire an expert witness in drug abuse

ESTIONS PRESENTED 1. Was trial counsel constitutionally ineffective because she failed to consult or hire an expert witness in drug abuse (rather than toxicology) to investigate the probability of reasonable doubt that the heroin ingested by the victim who suffered "serious bodily injury" was sold by the defendant, for the purposes of the penalty enhancement under 21 U.S.C. § 814(b)(1)(C)? Answer: YES. . 2. Did the district court commit reversible error when denying the Petitioner's § 2255 motion without considering the Petitioner's properly raised argument that trial counsel was ineffective for failing to investigate the distribution element of the Burrage defense? Answer: YES. 3. Did the courts below commit reversible error by denying a Certificate of Appealability regarding the Petitioner's § 2255 claim of ineffective assistance of counsel (specifically Ground 4)? Answer: YES. C) cy