context: In this case, respondent's access to a lawyer is the result of the State's decision, not the command of the United States Constitution."). Under Arizona law, a defendant is only entitled to counsel through the disposition of his or her first post-conviction petition.
citation_a.signal: see
citation_a.identifier: 501 U.S. 752, 752-53
citation_a.parenthetical: "Consequently, a petitioner cannot claim constitutionally ineffective assistance of counsel in [state post-conviction] proceedings."
citation_a.sentence: See Coleman, 501 U.S. at 752-53, 111 S.Ct. 2546 (“Consequently, a petitioner cannot claim constitutionally ineffective assistance of counsel in [state post-conviction] proceedings.”); Harris v. Vasquez, 949 F.2d 1497, 1513-14 (9th Cir.1990) (“Because [the petitioner] has no constitutional right to counsel in his earlier habeas proceedings, no error by his habeas counsel could constitute a sixth amendment violation or, therefore, cause.... ” (citation omitted)).
citation_b.signal: no signal
citation_b.identifier: 910 P.2d 1, 4
citation_b.parenthetical: "After counsel or the pro per defendant submits the post-conviction petition to the court and the trial court makes its required review and disposition, counsel's obligations are at an end."
citation_b.sentence: State v. Smith, 184 Ariz. 456, 910 P.2d 1, 4 (1996) (“After counsel or the pro per defendant submits the post-conviction petition to the court and the trial court makes its required review and disposition, counsel’s obligations are at an end.”). Because Cook had no constitutional right to counsel at the motion for rehearing stage, any errors by his counsel could not constitute cause to excuse the default.