at 530, 125 S.Ct. 2641 (citing 28 U.S.C. § 2244(b)(2)). 36 . Id. (citing 28 U.S.C. § 2244(b)(3)). 37 . Id. at 532, 125 S.Ct. 2641. 38 . Id. at 532 n.5, 125 S.Ct. 2641 (citation omitted). 39 . Martinez v. Ryan, 566 U.S. 1, 132 S.Ct. 1309, 182 L.Ed.2d 272 (2012). 40 . Trevino v. Thaler, — U.S. -, 133 S.Ct. 1911, 185 L.Ed.2d 1044 (2013). 41 . See Juniper v. Davis, 737 F.3d 288, 290 & n.2 (4th Cir. 2013); see also Mendoza v. Stephens, 783 F.3d 203, 210 (5th Cir. 2015) (per curiam) (mem.) (OWEN, J., concurring) (“Mendoza is statutorily entitled to conflict-free counsel at this stage in his habeas proceedings.”) (citing Juniper, 737 F.3d 288; Gray v. Pearson, 526 Fed.Appx. 331 (4th Cir. 2013); 18 U.S.C. § 3599(a)); Christeson v. Roper, - U.S. -, 135 S.Ct. 891, 895, 190 L.Ed.2d 763 (2015) (<HOLDING>). 42 . In re Paredes, 587 Fed.Appx. 805, 822-23
holding that relative to the threat that she posed physically separating tina cortez from her telephone taking her by the arm  escorting her from her home taking the keys to her home and locking the door and  placing her in the locked back seat of a patrol car was excessive force as well as an unlawful seizure under the fourth amendment holding that threatening employee to mind her own business investigating her videotaping her without her permission and forcing her to take polygraph could not be considered adverse employment actions because they had no effect on conditions of employment recognizing that grounds for substitution under  3599 exist when an attorneys personal interests prevent her from advancing her clients best arguments holding that an attorneys arguments are not evidence holding that attorneys and not clients choose the arguments to present