WHETHER TRIAL AND APPELLATE COUNSEL(S)' S INADEQUATE REPRESENTATION OF JESUS ANAYA CONSTITUTED, AT BEST, CONSTRUCTIVE DENIAL OF COUNSEL, WHERE TRIAL COUNSEL FAILED WOEFULLY TO SUBJECT THE GOVERNMENT'S CASE TO "STRICT ADVERSARIAL TESTING' WITH RESPECT TO JESUS ANAYA'S BASE OFFENSE LEVEL, AND APPELLATE COUNSEL FAILED TO ADEQUATELY ARGUE TO THE APPELLATE COURT, THAT (A) JESUS ANAYA'S CONSTITUTIONAL RIGHTS WERE VIOLATED IN THE DISTRACT COURT, AND FURTHER (B) JURISTS OF REASON WOULD CLEARLY DISAGREE WITH THE DECISION OF THE 'DISTRICT COURT', PURSUANT TO SLACK V. McDANIEL" (CITATIONS OMITTED).

Whether trial and appellate counsel's inadequate representation constituted constructive denial of counsel