Detailed Instructions: In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision. Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.
Problem:Mr. Muniz contends that, because Colorado defendants typically assert ineffective assistance claims upon collateral review, a collateral proceeding is effectively the first tier of review and counsel must be provided. Although, as Mr. Muniz notes, Halbert v. Michigan, 545 U.S. 605, 125 S.Ct. 2582, 162 L.Ed.2d 552 (2005), extended the right to counsel to a class of discretionary direct appeals, Halbert did not overrule clearly established Supreme Court precedent that individuals have no right to counsel in post-conviction proceedings. Id. at 2591-92. See, e.g., Coleman v. Thompson, 501 U.S. 722, 755, 111 S.Ct. 2546, 115 L.Ed.2d 640 (1991) ("[T]here is no right to counsel in state collateral proceedings."); Murray v. Giarratano, 492 U.S. 1, 13, 109 S.Ct. 2765, 106 L.Ed.2d 1 (1989) (<HOLDING>); Pennsylvania v. Finley, 481 U.S. 551, 557,
Holding statements: (A) holding that defendants have a right to counsel in criminal proceedings (B) holding no right to counsel for capital defendants in state habeas proceedings (C) holding that even capital prisoners have no constitutional right to counsel in habeas cases (D) recognizing the common practice of substituting specialized capital counsel for habeas petitions filed by capital defendants (E) holding that a parents statutory right to counsel in termination proceedings guarantees the right to effective counsel
Solution:
holding that defendants have a right to counsel in criminal proceedings