Brown v. Brown

Issue: Whether the Indiana procedure that allows trial-counsel Strickland v. Washington claims on direct appeal in one of two ways–defendants may assert the claims in their brief on direct appeal if they choose to make no further record in support of their claims or, if they wish to develop a record, defendants may suspend their direct appeal while they develop the factual record in the trial court–satisfies the Martinez-Trevino doctrine, which allows a federal habeas court to hear a substantial claim of ineffective assistance of trial counsel if a state denies a meaningful opportunity to raise the claim on direct appeal.