Stephen Corey Bryant v. Joel Anderson, Acting Director, South Carolina Department of Corrections, et al.

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 conduct 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-conviction counsel’s deficient performance establishes cause for the procedural default under Martinez v. Ryan, 566 U.S. 1 (2012)?