Whether the Sixth Circuit misapplied Rule 15 in denying Ivory's motion for a Certificate of Appealability (COA) such that its denial order should be summarily reversed and remanded

While pursuing habeas relief on an ineffective -assistance -of-counsel theory, George Ivory learned that the Government materially misrepresented the strength of its case to him during plea negotiations. Upon making that discovery, he moved to amend his habeas petition under Federal Rule of Civil Procedure 15 to add a claim that the guilty plea he entered in the underlying criminal case was induced by government misconduct, rendering it involuntary under Brady v. United States , 397 U.S. 742 (1970). But the district court denied his Rule 15 motion, reasoning that the claim he sought to add via amendment—i.e., a Brady claim —was barred by the statute of limitations and that, consequently, allowing him leave to amend would be futile. Ivory then moved the Sixth Circuit for a Certificate of Appealability (COA) concerning the district court’s procedural ruling, but the Sixth Circuit denied that motion too, reasoning that Ivory was not entitled assert his Brady claim because (in the court’s view) all reasonable jurists would agree that that claim “lack[ed] merit.” The question presented is whether the Sixth Circuit misapplied Rule 15 in denying Ivory’s motion for a COA such that its denial order should be summarily reversed and remanded so that the Sixth Circuit can apply the correct standard.