attempt to amend his § 2254 petition. Williams asserted, in his § 2254 petition, that the evidence of his guilt was so weak that his conviction violated his constitutional rights, and the state responded to this claim by asserting the affirmative defense of procedural default. Williams responded to this affirmative defense by asserting that appellate counsel’s failure to argue that Williams’s conviction violated his constitutional rights constituted cause that would excuse his procedural default of ground 1. In this context, Williams’s ineffective-assistance claim did not constitute an improper attempt to amend his § 2254 petition, and the magistrate and the district court should have addressed this argument. See Fed.R.Civ.P. 15(a)(1) — (2); cf. Williams, 557 F.3d at 1289-90, 1292 (<HOLDING>). For the foregoing reasons, we conclude that
holding that we do not consider arguments raised for the first time in a reply brief holding that bjecause the defendant has not presented these constitutional arguments to the district court in the first instance and because the appeal waiver narrowly circumscribes what he may appeal  we deem these  arguments waived holding that arguments cannot be made for the first time in reply papers holding that the district court possessed discretion to decline to review the  2254 petitioners arguments responding to the states assertion that his petition was untimely because the  2254 petitioner raised these arguments for the first time in his objections to the magistrate judges report and recommendation and failed to assert these arguments in a reply to the states response despite the fact that he was ordered to raise these arguments in a reply holding that arguments raised for the first time in a reply brief are forfeited