Read the following excerpt from a US court opinion:
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claim is a substantial one, which is to say that the prisoner must demonstrate that the claim has some merit — not that the prisoner will ultimately prevail on his claim. See Martinez, 132 S.Ct. at 1318-19 (citations omitted). Here, Abdur’Rahman met these requirements. 1. Petitioner alleges trial counsel was ineffective Abdur’Rahman argues that his trial counsel was ineffective in failing to address cumulative errors and correct the accomplice jury instruction. (See Pet’r State ment, R. 367, Page1D 520-23.) This is sufficient to meet the first prong of the Martinez/Trevino test. 2. Petitioner alleges post-conviction counsel was ineffective Martinez does not apply to claims of ineffective assistance of appellate counsel. See Atkins, 792 F.3d at 661 . However, as evidenced by the briefs in this
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What is the most suitable continuation to the opinion? Your options are:
A. holding that review of counsel ineffectiveness claims should be deferred until collateral review
B. holding that counsel cannot raise his or her own ineffectiveness
C. holding that the appellate standard of review of ineffectiveness claim is de novo
D. holding that ineffectiveness of postconviction counsel could establish cause to reopen judgment but ineffectiveness of postconviction appellate counsel could not
E. holding that where trial counsel was not ineffective appellate counsel was not ineffective for failing to raise claim of ineffectiveness of trial counsel
Reply with [A, B, C, D, E] only.