Renard Daniel, an Alabama death-row prisoner, sought federal habeas relief alleging ineffective assistance during the guilt and penalty phases of his capital trial. The district court granted a certificate of appealability on selected claims and denied relief. The Eleventh Circuit affirmed the denial of relief on Daniel’s guilt-phase ineffectiveness claim but reversed and vacated the ruling concerning his penalty-phase claim. The court held that the state court’s treatment of the penalty-phase allegations did not justify disposing of the claim without the factual development required by the record. Daniel’s allegations concerning counsel’s investigation and presentation of mitigation evidence were sufficiently substantial to require reconsideration under the federal habeas framework. The court remanded for the district court to reconsider discovery and conduct an evidentiary hearing on the penalty-phase claim, after which the district court was directed to reconsider that claim de novo. The court did not grant a new sentence or decide that counsel was constitutionally ineffective; it ordered further proceedings on that issue while leaving the guilt-phase denial intact.