Overstreet sought federal habeas relief from four kidnapping convictions arising from an armed robbery; Georgia’s later asportation rule in Garza applied because his convictions were still on direct review when it issued. The Eleventh Circuit held that appellate counsel was ineffective for failing to raise the clearly meritorious Garza argument, and the state court unreasonably applied Strickland in rejecting that claim. It reversed the denial of habeas relief and remanded with instructions to issue the writ as to kidnapping counts 2, 10, 17, and 26.