The "reasonable jurists" test was created only as
a threshold to discourage frivolous habeas appeals. It
was never intended as a sky-reaching wall over which
only a handful of certificate-of-appealability applicants
surmount. Statutorily, 28 U.S.C. § 2253(c) nowhere
suggests habeas appeals are to be the exception, not the
norm. This Court should correct circuits' pattern refusals
to issue COAs, and establish clearly how to go about
"demonstrating" that "reasonable jurists" exist who would
find an issue "debatable" or deserving of "encouragement
to proceed further." The circuits' unfaithfulness to the
test raises the first question. The second question is also
of national importance, and is the issue for which a COA
was sought:

I. Is the "reasonable jurists" test being administered
faithfully and consistently in circuits such as the Fourth,
in which COA applications have been denied over 8,400
times since 1996, while less than 100 have been granted; or,
in the Eighth, which has only granted 109 COAs between
January 2015 and January 2025; or, in the Sixth, which
has granted just 427 COAs in 2,372 cases in that same
time frame?

II. Do this Court's holdings in plea bargaining
precedents Lafler , Frye and Padilla dictate that federal
criminal defense attorneys should provide Sentencing
Guideline calculations when relaying plea offers to clients,
in order to avoid being ineffective under Strickland ?

Is the 'reasonable jurists' test being administered faithfully and consistently across federal circuits, and do Lafler, Frye, and Padilla precedents require criminal defense attorneys to provide Sentencing Guideline calculations during plea negotiations?