When a district court dismisses a federal habeas petition, a circuit court must issue a certificate of appealability for any claim in the petition whose dismissal is debatable among reasonable jurists. In contravention of this Court's precedent, Bryant's capital trial counsel failed to conduct a reasonable investigation and neither discovered nor presented available mitigating evidence of Bryant's brain damage from exposure to alcohol in utero, which substantially impaired his capacity to conform his conduc t to the requirements of the law. Bryant's post -conviction counsel then failed to pursue relief based on sentencing counsel's deficient investigation. Did the Fourth Circuit err when it denied a certificate of appealability on Bryant's claim that post -conv iction counsel's deficient performance establishes cause for the procedural default under Martinez v. Ryan , 566 U.S. 1 (2012)?

Did the Fourth Circuit err when it denied a certificate of appealability on Bryant's claim that post-conviction counsel's deficient performance establishes cause for the procedural default under Martinez v. Ryan, 566 U.S. 1 (2012)?