Marlon Edgardo Siguenza v. Fidencio N. Guzman, Warden
DueProcess HabeasCorpus
Did the Ninth Circuit's unreasoned denial of even a COA here so clearly misapply Buck's modest standard as to call for summary reversal?
In this noncapital habeas case, Marlon Siguenza alleges that his trial attorney was constitutionally ineffective for failing to investigate and present evidence at his murder trial that he suffered from post traumatic stress disorder, which the defense psychiatrist never screen ed him for . In support of the claim in state court while pro se , Siguenza alleged the symptoms he’d experienced, explained how they satisfied the diagnostic criteria for PTSD , and presented the letter of a psychiatrist who believed that Siguenza , if clinically examined, “might qualify ” for the diagnosis. The state court denied Siguenza’s claim without a hearing because “nothing … anywhere … in the record … support[ ed]” Siguenza’s allegation that he had PTSD . The federal district court did the same , speculating that there were other reasons to doubt that Siguenza had PTSD . Without analysis, the Ninth Circuit denied a certificate of appealability —effectively holding that the district court’s disposition of Siguenza’s claim was “not even debatable.” Buck v. Davis, 580 U.S. 100, 116 (2017) . Did the Ninth Circuit’s unreasoned denial of even a COA here so clearly misapply Buck ’s modest standard as to call for summary reversal?