What is the difference between a summary dismissal of a habeas claim and ineffectiveness of counsel?

MultiRegion, United States of America

The following excerpt is from Gebreamlak v. Vasquez, 12 F.3d 1106 (9th Cir. 1993):

Finally, Gebreamlak asserts a claim for ineffectiveness of counsel relating to an argument that he raised in his first petition--that the California appellate court failed to conduct an independent review of the record of his trial. Gebreamlak's petition yields no clue as to how his counsel purportedly was ineffective and, thus, does not explain how this claim differs from the claim he raised in his first petition. Summary dismissal of a habeas claim is appropriate "where the allegations in the petition are vague or conclusory." Hendricks v. Vasquez, 908 F.2d 490, 491 (9th Cir.1990) (internal quotations omitted). Gebreamlak's claim meets this standard.

The judgment of the district court is

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