Armis Arrendondo v. Dwight Neven

Opinion by Judge BERZON; Concurrence by Judge FERNANDEZ.

OPINION

BERZON, Circuit Judge:

Armis Arrendondo represented himself against theft charges at trial and was sentenced under Nevada’s habitual criminal statute, Nev.Rev.Stat. § 207.010, to two concurrent life sentences, with the possibility of parole after ten years. He contested his continued detention via a petition for habeas corpus under 28 U.S.C. § 2254, and now appeals the district court’s (1) denial, on the merits, of his claim of invalid waiver of his right to counsel and (2) dismissal as unexhausted of his claim of denial of the use…