This Court has repeatedly held that to receive a certificate of appealability ("COA"), a habeas petitioner need only show that "'jurists of reason could disagree with the district court's resolution of his constitutional claims or that jurists could conclude the issues presented are adequate to deserve encouragement to proceed further.'" Buck v. Davis, 137 S. Ct. 759, 773 (2017).

Petitioner David Howell testified at his murder trial that he accidentally killed his wife while intoxicated on methamphetamine, but his lawyer did not present expert testimony to corroborate his account. In her closing argument, the prosecutor called Howell's testimony "garbage" and said that "[u]sually you have a defense expert come in and testify to the alleged effects of methamphetamine . . . but you don't have any of that." Howell alleged in habeas that his lawyer provided ineffective assistance by failing to investigate, prepare and present evidence of his intoxication, including expert testimony.

Is the Ninth Circuit's denial of a COA on Howell's ineffective assistance of counsel claim contrary to this Court's jurisprudence?

Is the Ninth Circuit's denial of a COA on Howell's ineffective-assistance-of-counsel claim contrary to this Court's jurisprudence?