Does a prisoner have a right to effective counsel in collateral proceedings that provide the first occasion to raise a claim of ineffective assistance at trial?

question presented is: 1. Does a prisoner have a right to effective counsel in collateral proceedings that provide the first occasion to raise a claim of ineffective assistance at trial? ii The clear command of this Court’s jurisprudence is that state prisoners must primarily develop and litigate constitutional claims in state court. See Shinn v. Ramirez, 596 U.S. 366, 376 (2022) (“From the beginning of our country, criminal law enforcement has been primarily a responsibility of the States.”) (cleaned up); Harrington v. Richter, 562 U.S. 86, 103 (2011) (“[S]tate courts are the principal forum for asserting constitutional challenges to state convictions.”); Williams v. Taylor, 529 U.S. 420, 437 (2000) (“Federal courts sitting in habeas are not an alternative forum for trying facts and issues which a prisoner made insufficient effort to pursue in state proceedings.”). At the same time, this Court has long held that upon sufficient showing, a state, “at a minimum” must provide a defendant with expert assistance to “conduct an appropriate examination and assist in evaluation, preparation, and presentation of the defense.” Ake v. Oklahoma, 470 U.S. 68, 83 (1985). The holding in Ake recognizes the fundamental reality that “[c]riminal cases will arise where the only reasonable and available defense strategy requires consultation with experts or introduction of expert evidence, whether pretrial, at trial, or both.” Richter, 562 U.S. at 106. But, as described above, prisoners do not have a right to expert assistance in collateral proceedings, even though these proceedings often offer the sole opportunity to raise an ineffective assistance of counsel claim. The second question presented is: 2) Does a prisoner have a due process right to expert assistance in a collateral proceeding that offers the first opportunity to raise an ineffective assistance of counsel claim?