BENTON, Circuit Judge.
Michael A. Clay was convicted of rape in Arkansas. ARK.CODE ANN. § 5-14-103. After an unsuccessful appeal addressing insufficiency of the evidence, he sought post-conviction relief for ineffective assistance of counsel. ARK. R.CRIM. P. 37.1(A)(I). The trial court rejected his petition on the merits. On March 7, 2002, the Supreme Court of Arkansas refused to accept Clay's brief because his "abstract is deficient" and he "failed to include...
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