9th Cir.
11-56792

The court of appeals reversed a district court order denying a federal habeas petition and remanded the action for further proceedings. The court held that the Supreme Court’s enunciated standard for “cause” to excuse a state-court procedural default applies to all Sixth Amendment ineffective-assistance claims, both trial and appellate, that have been procedurally defaulted by ineffective counsel in the initial-review state-court collateral proceeding.