Did the Fourth Circuit err when it denied a certificate of appealability on Bryant's claim that post-conviction counsel's deficient performance establishes cause for the procedural default under Martinez v. Ryan, 566 U.S. 1 (2012)?

When a district court dismisses a federal habeas petition, a circuit court must issue a certificate of appealability for any claim in the petition whose dismissal is debatable among reasonable jurists. In contravention of this Court’s precedent, Bryant’s capital trial counsel failed to conduct a reasonable investigation and neither discovered nor presented available mitigating evidence of Bryant’s brain damage from exposure to alcohol in utero, which substantially impaired his capacity to conform his conduc t to the requirements of the law. Bryant’s post -conviction counsel then failed to pursue relief based on sentencing counsel’s deficient investigation. Did the Fourth Circuit err when it denied a certificate of appealability on Bryant’s claim that post -conv iction counsel’s deficient performance establishes cause for the procedural default under Martinez v. Ryan , 566 U.S. 1 (2012)? ii STATEMENT OF RELATED CASES Bryant v. Stirling , No. 23 -4, U.S. Court of Appeals for the Fourth Circuit. Judgment entered January 27, 2025. Bryant v. Stirling , No. 9:16 -cv-01423, U.S. District Court for the District of South Carolina. Judgment entered October 19, 2022. Bryant v. State, No. 2019 -000610, Supreme Court of South Carolina. Petition for a writ of certiorari denied May 11, 2021. Bryant v. State, No. 2016 -CP-43-828, Court of Common Pleas for Sumter County, South Carolina. Judgment entered January 4, 2019. Bryant v. State, No. 2016 -002228, Supreme Court of South Carolina. Judgment entered Feb ruary 9, 2017. Bryant v. State, No. 2016 -CP-43-829, Court of Common Pleas for Sumter County, South Carolina. Judgment entered July 15, 2016. Bryant v. South Carolina , No. 15 –6215, Supreme Court of the United States. Petition for a writ of certiorari denied Nov ember 30, 2015. Bryant v. State, No. 2013 -000518, Supreme Court of South Carolina. Petition for a writ of certiorari denied March 4, 2015. Bryant v. State, No. 201l -CP-43-00901, Court of Common Pleas for Sumter County, South Carolina. Judgment entered February 14, 2013. State v. Bryant , No. 2008 -103130, Supreme Court of South Carolina. Judgment entered January 7, 2011. State v. Bryant , No. 2006 -GS-43-000699, Court of Common Pleas for Sumter County, South Carolina. Judgment entered September 11, 2008.