Where there was evidence of a history of the defendant's mental health issues and mental health hospitalization and trial counsel failed to even initiate an investigation into the defendant's mental health, including as it related to the alleged crime of murder and the defendant's seemingly inculpatory post-arrest conduct successfully used against him at trial, did the First Circuit err in its cursory order denying a certificate of appealability on a claim of ineffective assistance of counsel?

Whether trial counsel's failure to investigate the defendant's history of mental illness and mental health issues, including as it related to the alleged crime and the defendant's seemingly inculpatory post-arrest conduct, constituted ineffective assistance of counsel