1. When a state trial court fails to conduct a Faretta colloquy before sentencing a defendant without counsel—a fundamentally unfair structural error that would require automatic reversal—is appellate counsel ineffective for failing to raise the issue on direct appeal?

2. When a habeas petitioner asserts ineffective assistance of counsel resulting in a fundamentally unfair structural error (such as deprivation of the right to counsel at sentencing), must that petitioner also demonstrate actual prejudice, even when doing so is inherently impossible?

When a state trial court fails to conduct a Faretta colloquy before sentencing a defendant without counsel, is appellate counsel ineffective for failing to raise the issue on direct appeal?