Samuel Ambrose v. Kenneth Romanowski

OPINION

McKEAGUE, Circuit Judge.

Samuel Ambrose was convicted of second-degree murder in 1979 after an altercation outside of a bar in Detroit. The district court denied his petition for a writ of habeas corpus, and issued a certificate of appealability on two of his twelve claims: (1) the series of jury instructions — an error followed- by a retraction and two later clarifications — resulted in an unfair trial in violation of the Due Process Clause; and (2) ineffective assistance of counsel during the plea process in violation of the Sixth Amendment. The state court addressed the…