Michael Williams v. Nick Ludwick

SMITH, Circuit Judge.

In 1998, an Iowa state jury convicted Michael Williams of first-degree murder, for which he was sentenced to life imprisonment without the possibility of parole. After exhausting direct and collateral appeals, Williams petitioned for habeas relief in federal district court. 1 Williams alleged that conflicts of interests rendered his trial counsel ineffective and that his appellate counsel was ineffective for failing to pursue some of his conflict-of-interest claims. The district court denied relief. We affirm.

I. Background

The Iowa Court of Appeals succinctly summarized…