Whether inadequate assistance of counsel at initial-review collateral proceedings may establish cause for a prisoner's procedural default of a claim of ineffective assistance at trial

QUESTION PRESENTED Petitioner filed a petition for habeas corpus relief, where he raised a claim of actual innocence, and numerous claims of ineffectiveness of trial counsel, in which his post-conviction counsel caused to be procedurally defaulted; in which the Third Circuit stated "cannot be excused pursuant to Martinez v. Ryan, 566 U.S 1 2012)" The case thus presents the following questions; 1. SHOULD THIS COURT GRANT THE WRIT TO RESOLVE A : CONFLICT BETWEEN THE COURTS OF APPEALS REGARDING AN IMPORTANT QUESTION THAT THIS COURT EXPLICITLY RESERVED IN MARTINEZ V. RYAN, 132 S.Ct. 1309 (2012) WHETHER INADEQUATE ASSISTANCE OF COUNSEL AT INITIAL-REVIEW COLLATERAL PROCEEDINGS MAY ESTABLISH CAUSE FOR A PRISONER'S PROCEDURAL DEFAULT OF A CLAIM OF INEFFECTIVE ASSISTANCE AT TRIAL. II. THIS COURT SHOULD GRANT THE WRIT TO SOLVE A CONFLICT BETWEEN THE THIRD CIRCUIT COURT OF APPEAL REGARDING AN IMPORTANT QUESTION THAT THIS COURT EXPLICITLY POINTED OUT IN MARTINEZ V. RYAN, 132 S.CT. 1309 WHETHER PETITIONER CAN ESTABLISH CAUSE FOR A PROCEDURAL DEFAULT THAT OCCURRED DURING STATE COLLATERAL POST-CONVICTION PROCEEDINGS UNDER §2254(i) III. THIS COURT SHOULD GRANT THE WRIT TO DECIDE WHETHER THE STATE AND FEDERAL COURT DEPRIVE PETITIONER OF HIS PROCEDURAL DUE PROCESS WHEN IT DETERMINED THAT HIS NUMEROUS CLAIMS MERITLESS WITHOUT AFFORDING HIM THE OPPORTUNITY TO SUBSTANTIATE HIS CLAIMS AT AN EVIDENTIARY HEARING. i