Applicant Phillip Kevin Bush, a Colorado state prisoner proceeding pro se, filed an application under 28 U.S.C. § 2254 seeking relief from his state-court convictions. The federal district court denied relief and declined to issue a certificate of appealability (COA). See 28 U.S.C. § 2253(c)(1)(A) (requiring COA to proceed on appeal). This court granted a COA on whether the plea agreement...
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