Mallard v. Cain

DENNIS, Circuit Judge:

Darren Mallard, Louisiana prisoner # 366098, was convicted of possession of more than four-hundred grams of cocaine in 1996 and subsequently sentenced to forty years in prison as a third-time felony offender in 2001. The district court denied Mallard’s 28 U.S.C. § 2254 petition. Mallard appealed the denial, and the district court granted a certificate of appealability (COA) on two issues: (1) whether the Louisiana district court’s determination that there was a valid waiver of counsel as to one of Mallard’s predicate offenses was unreasonable in light of the evidence…