Must a pro se petitioner alleging a complete denial of counsel specifically cite Cronic to exhaust his claim in the state court?

QUESTIONS PRESENTED Strickland v. Washington, 466 U.S. 668 (1984), held a criminal defendant alleging ineffective assistance of counsel must prove deficient performance and prejudice. United States v. Cronic, 466 U.S. 648 (1984), decided the same day, held that for a complete denial of counsel at a critical stage, prejudice is presumed. The questions presented are: Must a pro se petitioner alleging a complete denial of counsel specifically cite Cronic to exhaust his claim in the state court? If a detained criminal defendant has no communication with a lawyer for 14 months after arrest, is prejudice presumed? ii RULE 14(B) STATEMENT All parties appear in the caption of the case on the cover page. The following proceedings are directly related to this case within the meaning of Rule 14.1(b)Gii): 1. State v. Russell, No. 07-0-673WSY (Hinds Co., Miss., Circuit Ct.) Gudgment following jury verdict entered January 30, 2009) 2. Russell v. State, No. 2009-KA-01628-COA (Miss. Ct. App.) (direct appeal) (opinion affirming conviction entered August 16, 2011, and reported at 79 So. 3d 529; motion for rehearing denied November 8, 2011) 3. Russell v. State, No. 2009-CT-01628-SCT (Miss.) (order denying petition for writ of certiorari entered February 9, 2012) 4, Russell v. State, No. 2009-M-01623 (Miss.) (post-conviction proceedings) (order denying post-conviction relief entered February 13, 2014) 5. Russell v. Denmark, No. 3:14-cv-00225 (S.D. Miss.) (federal habeas proceedings) (final judgment granting habeas relief entered March 24, 2021, and reported at 528 F.Supp.3d 482) 6. Russell v. Denmark, No. 21-60344 (5th Cir.) Gudgment reversing and rendering entered May 18, 2023, and reported at 68 F.4th 252) ili