Whether an ineffective assistance claim may be based on counsel's failure to exercise a state-law right to introduce residual doubt evidence at a capital sentencing?

QUESTIONS PRESENTED Capital Case 1. Whether an ineffective assistance claim may be based on counsel’s failure to exercise a state-law right to introduce residual doubt evidence at a capital sentencing? 2. Whether counsel provides ineffective assistance at capital sentencing if they fail to establish the defendant’s lesser moral culpability by demonstrating that he did not kill a victim, even if the lesser culpability proof fails to negate all aggravating (eligibility) factors? 3. Whether it constitutes deficient performance under Strickland v. Washington, 466 U.S. 668, 688 (1984), if trial counsel postpones their preparations for sentencing until a brief post-guilt phase recess? And if deficient, can counsel’s performance be excused, if omitted mitigation evidence fails to explain why the defendant committed the offense? ‘ LIST OF