1. Where a state habeas court, in a non-alternative holding, considers the merits of a defaulted counsel claim to decide whether statutorily required post-conviction counsel was ineffective for omitting the claim, may a federal habeas court ignore the antecedent ruling on federal law to find the underlying claim defaulted?

2. Could reasonable jurists debate whether a state court may apply the state's Atkins statute in a way precluding consideration of current clinical standards?

Where a state habeas court considers the merits of a defaulted counsel claim to decide whether statutorily required post-conviction counsel was ineffective for omitting the claim, may a federal habeas court ignore the antecedent ruling on federal law to find the underlying claim defaulted?