Does the rule established in Martinez V. Ryan, 132 S.CT. 1309 (2012) and Trevino V. Thaler 133 S. CT 1911, 1921 (2013) that ineffective state appellate counsel can be seen as cause to overcome the procedural default of substantial ineffective assistance of trial counsel. Claim also applies to procedurally defaulted, but substantial, ineffective assistance of appellate counsel claims. Martinez v. Ryan held that its exception to the Coleman v. Thompson rule was limited to claims of ineffective assistance of trial counsel and that Coleman would govern in all other circumstances, which necessarily includes claims of ineffective assistance of appellate counsel. Should Martinez be overruled to the extent of that limitation, thereby extending its exception? To appellate counsel claims?
Does the rule established in Martinez v. Ryan and Trevino v. Thaler apply to procedurally defaulted ineffective assistance of appellate counsel claims?