Charles Gregory Clark was convicted of robbing and murdering a convenience-store owner and sentenced to death after an 11-to-1 jury recommendation; Clark confessed, and physical evidence strongly tied him to the crime. In federal habeas proceedings, Clark argued that trial counsel was ineffective for failing to object when jurors saw him wearing restraints, but the district court found the claim procedurally defaulted after state postconviction counsel abandoned it. The Eleventh Circuit considered Clark’s reliance on Martinez v. Ryan, which can excuse some defaults of substantial trial-counsel claims, but affirmed without deciding whether the exception applied. It held Clark had not shown a substantial ineffective-assistance claim because he failed to establish Strickland prejudice: the presumption sometimes used for visible shackling on direct appeal did not apply to this collateral claim, and the overwhelming evidence left no reasonable probability that jurors seeing a leg brace affected either the verdict or death recommendation. The judgment denying federal habeas relief was affirmed.