Full opinion text
MARTIN, Circuit Judge: Petitioner Renard Marcel Daniel, an Alabama prisoner on death row, appeals the District Court’s denial of his 28 U.S.C. § 2254 petition for writ of habeas corpus. The District Court granted Mr. Daniel a certifícate of appealability (COA) as to the following issue: “Whether trial counsel was ineffective during Daniel’s trial at both the penalty and guilt phase.” Mr. Daniel narrowed the focus of his briefing in this Court to trial counsel’s failure to investigate and present mitigation evidence at the penalty phase of his capital trial. Mr. Daniel’s childhood was nightmarish by any standard. When he was only three years old, his mother killed his biological father with a shotgun while Mr. Daniel was in the home. Beginning before his tenth birthday, and for several years, Mr. Daniel was repeatedly sexually assaulted by his stepfather and was forced to engage in sex acts with his siblings while his stepfather watched. School records show that Mr. Daniel was placed in special education classes. His test scores are consistent with borderline intellectual disability, and his adaptive functioning is consistent with a person with intellectual disability. A postconviction neuropsychological evaluation confirmed Mr. Daniel suffered from lifelong borderline intellectual functioning, significant impairments in adaptive function both prior to and after age eighteen, childhood dissociative disorder with psychotic features (related to daily sexual, physical, and emotional abuse), and depression since childhood. Mr. Daniel specifically pleaded all of these facts, and more, in his second amended state habeas petition filed pursuant to Alabama Rule of Criminal Procedure 32. All of this mitigation evidence about Mr. Daniel’s “background and character is relevant because of the belief, long held by this society, that defendants who commit criminal acts that are attributable to a disadvantaged background ... may be less culpable than defendants who have no such excuse.” Penry v. Lynaugh, 492 U.S. 302, 319, 109 S.Ct. 2934, 2947, 106 L.Ed.2d 256 (1989) (quotation marks omitted). But Mr. Daniel’s sentencing jury and judge heard none of this mitigation evidence. According to Mr. Daniel, this is because his trial counsel did not conduct a constitutionally adequate investigation into his background. Mr. Daniel also asserts that trial counsel’s deficient performance prejudiced the outcome of his penalty phase. While trial counsel presented some mitigation evidence during the penalty phase through Mr. Daniel’s mother, the description, details, and depth of abuse in Mr. Daniel’s background that he brought to the attention of the state courts in his habeas proceedings far exceeded anything the sentencing jury and judge were told. Nonetheless, the Alabama state courts denied Mr. Daniel’s claim without discovery or an evidentiary hearing, finding that he failed to specifically and sufficiently plead his ineffective assistance of counsel claim under Alabama Rules of Criminal Procedure 32.6(b) and 32.7(d). The District Court denied habeas relief. After thorough review of the record and oral argument, we affirm the District Court’s denial of Mr. Daniel’s guilt phase ineffective assistance of counsel claim, but reverse the District Court’s ruling as to Mr. Daniel’s penalty phase ineffective assistance of counsel claim and remand for an evidentia-ry hearing. I. BACKGROUND A. OFFENSE AND CHARGES On September 26, 2001, John Brodie and Loretta McCulloch were shot to death in their apartment in Birmingham, Alabama. See Daniel v. State, 906 So.2d 991, 994-95 (Ala.Crim.App.2004) (Daniel I). According to the trial testimony of George Jackson — a friend of Mr. Daniel’s who lived in the same apartment complex as Mr. Daniel, Mr. Brodie, and Ms. McCulloch — Mr. Daniel shot Mr. Brodie and Ms. McCulloch following a card game after Mr. Brodie used racial slurs and Ms. McCulloch taunted Mr. Daniel by refusing to return his cigarettes. About twelve hours after the shooting, Mr. Jackson reported the crime to the police, exculpating himself and implicating Mr. Daniel. Mr. Daniel was arrested later that day for the murders based on the information provided by Mr. Jackson. He was indicted on March 8, 2002, for capital murder under Alabama Criminal Code § 13A-5-40(a)(10). B. TRIAL Because Mr. Daniel was not able to afford an attorney, Jefferson County Circuit Judge Tommy Nail appointed Katheree Hughes to represent Mr. Daniel on October 15, 2001. Judge Nail later appointed Danita Haskins on July 19, 2002, to assist Mr. Hughes. Mr. Daniel’s trial began on March 10, 2003. The state presented the testimony of Mr. Jackson implicating Mr. Daniel, as well as the testimony of other witnesses and forensic and physical evidence that corroborated Mr. Jackson’s testimony. Mr. Daniel testified that it was Mr. Jackson who shot Mr. Brodie and Ms. McCulloch. On March 14 at 2:10 p.m., the jury found Mr. Daniel guilty of capital murder. C.PENALTY PHASE Five minutes later, the trial court tried to start the sentencing hearing before the jury, but trial counsel requested an adjournment until the following morning “in order to get enough time to go through all the information [trial counsel] need[ed] to go through” to start the sentencing hearing. The trial court gave the defense thirty minutes. The state presented no additional witnesses during the penalty phase before the jury, instead relying on evidence presented during the guilt phase and documentary exhibits to prove two of the three aggravating circumstances it asserted: (1) Mr. Daniel was on probation when the offense occurred, Ala.Code § 13A-5-49(l); and (2) he previously was convicted of a felony involving the use or threat of violence, id. § 13A-5-49(2). In closing arguments, the state elaborated on the second circumstance, telling the jury that Mr. Daniel’s earlier conviction for second degree burglary involved “entering or remaining in someone’s home for the purpose of committing rape.” Because he now stood convicted of murdering both Mr. Brodie and Ms. McCulloch, the state also told the jury that Mr. Daniel had a third aggravating circumstance, that is killing two people during one course of conduct. See id. § 13A-5-49(9). The only witness defense counsel presented was Carolyn Daniel, Mr. Daniel’s mother. In her brief testimony, which occupies only ten double-spaced pages of transcript, Mrs. Daniel touched on some of the low points in her son’s life. She told the jury that Mr. Daniel had Attention Deficit Hyperactivity Disorder (ADHD) and dyslexia; that he dropped out of school in the tenth grade; and that Mr. Daniel’s biological father died when Mr. Daniel was three. Mrs. Daniel also testified that Mr. Daniel’s stepfather, Earnest Western, “abused [him] and I didn’t know about it for a long time.” She described only one specific instance of abuse. When Mr. Daniel was about twelve years old Mrs. Daniel said she left him “[o]ne night” with his stepfather and, when she got home, Mr. Daniel told her “that he had gotten a beating by his stepdad” and that he had blood in his urine. When she took Mr. Daniel to the hospital, “[i]t was discovered that one of his kidneys had been damaged from the beating.” As a result, protective services removed Mr. Daniel and his two sisters from the home for about ten months, and Mr.. Daniel was placed in a group home. When the family reunited, Mrs. Daniel says Mr. Daniel was “withdrawn” and “always seem[ed] like he was hurting on the inside.” Mr. Daniel started drinking beer at about age sixteen, and “on one occasion” Mrs. Daniel found marijuana in his room. Finally, Mrs. Daniel pleaded to the jury for her son’s life. Two hours and twenty minutes after the penalty phase began, the jury returned a 10 to 2 verdict for death. Then on May 9, 2003, the trial court conducted a sentencing hearing without the jury, which is the procedure called for by Alabama law. See Ala.Code § 13A-5-47. The state presented no additional evidence of aggravating circumstances, but it did present the testimony of Spencer Sims, Ms. McCulloch’s father, who spoke of forgiveness and asked for a life sentence. The defense called Carolyn Daniel, as it had during the penalty phase, and called Mr. Daniel’s sister, Tammi Daniel, as well. Both asked the trial court to spare Mr. Daniel’s life. After hearing this testimony, the trial court accepted the jury’s recommendation and sentenced Mr. Daniel to death. Immediately after imposing the sentence, the trial court granted trial counsel’s request to be relieved of any further responsibility in Mr. Daniel’s case. D. DIRECT APPEAL The trial court then appointed James ■Kendrick and Steven Wallace to represent Mr. Daniel on appeal. The Court of Criminal Appeals remanded the case due to an improper sentencing order. Daniel I, 906 So.2d at 1001-02. Specifically, the court found that the trial court’s written sentencing order did not comply with state law, which requires the trial court to make “specific written findings concerning the existence or nonexistence” of aggravating and mitigating circumstances. Id. ■ (quoting Ala.Code § 13A-5-47(d)). On remand, the trial court entered an order finding three aggravating circumstances: (1) the capital offense was committed while the defendant was under a sentence of imprisonment; (2) Mr. Daniel had already been convicted of a felony involving the use of violence to the person, here, “Defendant pled guilty to burglary 2 [degree] with the intent to commit rape”; and (3) the “Defendant intentionally caused the death of two or more persons by one act or pursuant to one scheme or course of conduct.” The trial court found no statutory mitigating circumstances. After summarizing the brief testimony of Carolyn Daniel given before the jury during the penalty phase of Mr. Daniel’s trial, as well as the testimony of Carolyn Daniel, Spencer Sims, and Tammi Daniel given at the separate sentencing hearing before the judge, the trial court found “the aggravating- circumstances outweigh the mitigating circumstances and [are] sufficient to uphold the Jury’s recommendation of punishment.” On return after remand, the Alabama Court of Criminal Appeals affirmed Mr. Daniel’s convictions and death sentence in August 2004. Daniel I, 906 So.2d at 1004. The Alabama Supreme Court denied his petition for certiorari on February 18, 2005. Id. at 991. The United States Supreme Court denied certiorari review. Daniel v. Alabama, 546 U.S. 846, 126 S.Ct. 96, 163 L.Ed.2d 112 (2005) (mem.). E. STATE POSTCONVICTION On February 14, 2006, Mr. Daniel, through new counsel, timely filed a state petition for postconviction relief pursuant to Rule 32 of the Alabama Rules of Criminal Procedure. His first Rule 32 petition specifically alleged the ineffectiveness of his trial counsel, including allegations that trial counsel were ineffective for failing to conduct a thorough investigation for the penalty phase, which would have uncovered material admissible evidence about Mr. Daniel’s excruciating past. Mr. Daniel’s Rule 32 petition also pleaded that he was prejudiced by trial counsel’s errors and omissions. Ten days after filing the Rule 32 petition, postconviction counsel moved for discovery seeking, among other things, mental health, social services, and school records relevant to the ineffective assistance of trial counsel allegations in the Rule 32 petition. In May 2006, the state filed a motion to dismiss, which the postconviction court granted without giving Mr. Daniel an opportunity to respond or acknowledging his discovery request. After Mr. Daniel filed a motion for reconsideration, the postcon-viction court granted him permission to submit an amended petition. In October 2006 Mr. Daniel filed his first amended Rule 32 petition. He also filed an amended motion for discovery in order to vindicate, among other things, claims that trial counsel were ineffective for failing to investigate and present available mitigating evidence, failing to procure the expert assistance of a mental health/mitigation expert, and failing to challenge Mr. Daniel’s second degree burglary conviction. Following oral argument to determine whether an evidentiary hearing was warranted, the state postconviction court granted Mr. Daniel leave to file a second amended petition. Without the benefit of discovery or an evidentiary hearing, Mr. Daniel filed a 96-page second amended Rule 32 petition in August 2007. This second amended- petition was filed together with 21 exhibits, including school, mental health, and social service records, along with other documentary evidence, all in support of Mr. Daniel’s allegations that if trial counsel had conducted even a cursory investigation of his background, they would have discovered compelling mitigation evidence. In December 2008, the Rule 32 trial court entered an order summarily dismissing the second amended Rule 32 petition, again without having permitted any discovery and having conducted no evidentiary hearing. The postconviction court dis-, missed the petition on several grounds without specifying which ground applied to which claims. Mr. Daniel appealed the dismissal to the Alabama Court of Criminal Appeals, which affirmed in a reasoned opinion. See Dan iel v. State, 86 So.3d 405 (Ala.Crim.App.2011) (Daniel II). The Court of Criminal Appeals acknowledged that the postconviction trial “court stated alternative grounds for denying relief on Daniel’s claims of ineffective assistance of counsel.” Id. at 414. But the Court of Criminal Appeals affirmed the trial court’s summary dismissal of Mr. Daniel’s petition at the pleading stage “[f]or the reasons set out in [the Court of Criminal Appeals] opinion”— mainly that Mr. Daniel failed to sufficiently and specifically plead his claims under Alabama Rule of Criminal Procedure 32.6(b) and 32.7(d). Id. at 414, 429-40. The Court of Criminal Appeals also expressed disagreement with the trial court’s other reasoning. Id. at 414 & n. 3. Thus, this is not a ease in which a state trial and appellate court agreed on the reasons for denying a postconviction petition. The Alabama Supreme Court denied Mr. Daniel’s petition for writ of certiorari in summary fashion, so we agree with the State of Alabama that the Alabama Court of Criminal Appeals decision in Daniel II must be the focus of our evaluation when applying the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). See McGahee v. Ala. Dep’t of Corr., 560 F.3d 1252, 1261 n. 12 (11th Cir.2009). F. FEDERAL PETITION Mr. Daniel timely filed his first and only federal petition for writ of habeas corpus in July 2012. He also filed motions for discovery and an evidentiary hearing in the District Court. The District Court denied relief without an evidentiary hearing or discovery, but did grant Mr. Daniel a certificate of appealability on his ineffective assistance of counsel claims. II. STANDARD OF REVIEW We review de novo the District Court’s ultimate decision denying a 28 U.S.C. § 2254 petition. Ray v. Ala. Dep’t of Corr., 809 F.3d 1202, 1207 (11th Cir.2016). “We review the District Court’s legal conclusions de novo and its factual findings for clear error.” Hardwick v. Sec’y, Fla. Dep’t of Corr., 803 F.3d 541, 545 (11th Cir.2015). Because Mr. Daniel filed his federal ha-beas petition after April 24, 1996, our review is governed by AEDPA. See Pope v. Sec’y for Dep’t of Corr., 680 F.3d 1271, 1281 (11th Cir.2012). Generally, AEDPA bars federal courts from granting habeas relief to a state habeas petitioner on a claim that was adjudicated on the merits in state court unless the state, court’s adjudication: (1) resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States; or (2) resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding. 28 U.S.C. § 2254(d). “Clearly established” . in § 2254(d)(1) “refers to the holdings, as opposed to the dicta,” of the Supreme Court’s, cases at the time of the relevant state court decision. Williams v. Taylor, 529 U.S. 362, 412, 120 S.Ct. 1495, 1523, 146 L.Ed.2d 389 (2000). “Contrary to” means the state court applied “a rule different from the governing law set forth in [Supreme Court] cases, or [] it decide[d] a case differently than [the Supreme Court] ha[s] done on a set of materially indistinguishable facts.” Bell v. Cone, 535 U.S. 685, 694, 122 S.Ct. 1843, 1850, 152 L.Ed.2d 914 (2002). An “unreasonable application” under § 2254(d)(1) occurs when a state court decision (1) “identifies the correct governing legal rule from [the Supreme] Court’s cases but unreasonably applies it to the facts of the particular state prisoner’s case,” or (2) “either unreasonably extends a legal principle from [Supreme Court] precedent to a néw context where it should not apply or unreasonably refuses to extend that principle to a new context where it should apply.” Williams, 529 U.S. at 407, 120 S.Ct. at 1520. The “ ‘unreasonable application’ inquiry ... ask[s] whether the state court’s application of clearly established federal law was objectively unreasonable,” id. at 409, 120 S.Ct. at 1521, which “requires the state court decision to be more than incorrect or erroneous.” Lockyer v. Andrade, 538 U.S. 63, 75, 123 S.Ct. 1166, 1174, 155 L.Ed.2d 144 (2003); see also Harrington v. Richter, 562 U.S. 86, 101, 131 S.Ct. 770, 786, 178 L.Ed.2d 624 (2011) (“A state court’s determination that a claim lacks merit precludes federal habeas relief so long as ‘fairminded jurists could disagree’ on the correctness of the state court’s decision.” (quoting Yarborough v. Alvarado, 541 U.S. 652, 664, 124 S.Ct. 2140, 2149, 158 L.Ed.2d 938 (2004))). However, AEDPA does not “prohibit a federal court from finding an application of a principle unreasonable when it involves a set of facts different from those of the case in which the principle was announced. The statute recognizes, to the contrary, that even a general standard may be applied in an unreasonable manner.” Panetti v. Quarterman, 551 U.S. 930, 953, 127 S.Ct. 2842, 2858, 168 L.Ed.2d 662 (2007) (citation and quotation omitted). Further, “review under § 2254(d)(1) is limited to the record that was before the state court that adjudicated the prisoner’s claim on the merits.” Greene v. Fisher, 565 U.S.-,-, 132 S.Ct. 38, 44, 181 L.Ed.2d 336 (2011). Section 2254(d)(1) requires federal courts to “focus[ ] on what a state court knew and did” and to evaluate the reasonableness of the state court’s decision “against [the Supreme] Court’s precedents as of the time the state court rendered] its decision.” Cullen v. Pinholster, 563 U.S. 170, 182, 131 S.Ct. 1388, 1399, 179 L.Ed.2d 557 (2011) (quotation omitted). When evaluating whether a state court’s decision “was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding” under § 2254(d)(2), “[w]e may not characterize ... state-court factual determinations as unreasonable ‘merely because [we] would have reached a different conclusion in the first instance.’ ” Brumfield v. Cain, 576 U.S. -, -, 135 S.Ct. 2269, 2277, 192 L.Ed.2d 356 (2015) (second alteration in original) (quoting Wood v. Allen, 558 U.S. 290, 301, 130 S.Ct. 841, 849, 175 L.Ed.2d 738 (2010)). Section 2254(d)(2), like § 2254(d)(1), requires that federal courts afford state court factual determinations “substantial deference.” Id. If “[reasonable minds reviewing the record might disagree about” the state court factfinding in question, “on habeas review that does not suffice to supersede” the state court’s factual determination. Rice v. Collins, 546 U.S. 333, 341-42, 126 S.Ct. 969, 976, 163 L.Ed.2d 824 (2006). We also presume findings of fact made by state courts are correct, unless a petitioner rebuts that presumption by clear and convincing evidence. 28 U.S.C. § 2254(e)(1). “When considering a determination of a mixed question of law and fact, such as a claim of ineffective assistance of counsel, the statutory presumption of correctness applies to only the underlying factual determinations.” Tanzi v. Sec’y, Fla. Dep’t of Corr., 772 F.3d 644, 651 (11th Cir.2014). In sum, AEDPA “erects a formidable barrier to federal habeas relief for prisoners whose claims have been adjudicated in state court.” White v. Wheeler, 577 U.S. -,-, 136 S.Ct. 456, 460, 193 L.Ed.2d 384 (2015) (per curiam) (quotation omitted). But the Supreme Court has explained, “[e]ven in the context of federal habeas, deference does not imply abandonment or abdication of judicial review.” Miller-El v. Cockrell, 537 U.S. 322, 340, 123 S.Ct. 1029, 1041, 154 L.Ed.2d 931 (2003). “Deference does not by definition preclude relief.” Id. “[I]f a convicted state criminal defendant can show a federal ha-beas court that his conviction rests upon a violation of the Federal Constitution, he may well obtain a writ of habeas corpus that requires a new trial, a new sentence, or release.” Trevino v. Thaler, 569 U.S. -, -, 133 S.Ct. 1911, 1917, 185 L.Ed.2d 1044 (2013). Once a federal court determines that a state court decision is unreasonable under § 2254(d), “we are unconstrained by § 2254’s deference and must undertake a de novo review of the record.” Adkins v. Warden, Holman CF, 710 F.3d 1241, 1255 (11th Cir.2013) (quotation omitted). III. DISCUSSION Because the Alabama Court of Criminal Appeals issued a reasoned opinion that adjudicated Mr. Daniel’s penalty phase ineffective assistance of counsel claim on the merits, we follow a two-step analysis from Richter, 562 U.S. at 102, 131 S.Ct. at 786. First, we “determine what arguments or theories support[ ] ... the state court’s decision”; second, we “ask whether it is possible fairminded jurists could disagree that those arguments or theories are inconsistent with the holding in a prior decision of th[e] [Supreme] Court.” Id. The Court of Criminal Appeals correctly identified Strickland v. Washington, 466 U.S. 668, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984), as the proper standard for evaluating ME Daniel’s ineffective assistance of counsel claims. Daniel II, 86 So.3d at-415. However, in doing so, the Court of Criminal Appeals dissected Mr. Daniel’s .penalty phase ineffective assistance of’counsel claims into thirteen sub-parts, and in that way concluded most of them were properly dismissed under Alabama Rule of Criminal Procedure 32.6(b), because Mr. Daniel failed to plead his claim with sufficient specificity, id. at 429-30, 434, 436-38, 440, or under Rule 32.7(d) because Mr. Daniel failed to state a claim, id. at 429-31, 433-35, 437-40. Summary dismissals under Rules 32.6(b) and 32.7(d) are adjudications on.the merits and subject to AEDPA review. See Frazier v. Bouchard, 661 F.3d 519, 525 (11th Cir.2011); Borden v. Allen, 646 F.3d 785, 808 (11th Cir.2011). Thus, AEDPA requires us “to evaluate whether the Court of Criminal Appeals’s determination that [Mr. Daniel’s] relevant ineffective assistance of counsel claims were due to be dismissed for failure to state a claim with sufficient specificity under Rule 32.6(b) was ‘contrary to, or involved an unreasonable application of, clearly established Federal law,’ ” Borden, 646 F.3d at 817-18 (quoting 28 U.S.C. § 2254(d)(1)), or whether it “resulted in a decision that was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding,” 28 U.S.C. § 2254(d)(2). See also Powell v. Allen, 602 F.3d 1263, 1273 (11th Cir.2010) (per curiam) (“AED-PA limits our review to whether the state court’s determination that Powell failed to plead sufficient facts in his Rule 32 petition to support a claim of ineffective assistance of counsel was contrary to or an unreasonable application of Supreme Court precedent.”). We must therefore answer two questions to resolve this habeas appeal. First, whether Mr. Daniel’s second amended Rule 32 petition and its attached exhibits pleaded enough specific facts that, if proven, amount to a valid penalty phase ineffective assistance of counsel claim. Second, if we answer the first question in the affirmative, we must determine whether the Alabama Court of Criminal Appeals’s decision to the contrary was unreasonable under § 2254(d). In conducting our evaluation, we are mindful that “at the pleading stage of Rule 32 proceedings [in Alabama], a Rule 32 petitioner does not have the burden of proving his claims,” Ford v. State, 831 So.2d 641, 644 (Ala.Crim.App.2001), and that facts Mr. Daniel alleged in his Amended Rule 32 petition and supporting exhibits are assumed to be true under Alabama law, see Ex parte Williams, 651 So.2d 569, 572-73 (Ala.1992). However, to meet the pleading requirements of Rule 32.6(b), Mr. Daniel’s petition had to identify the specific acts or omissions of counsel that are alleged not to have been the result of reasonable professional judgment ... [and] plead specific facts indicating that [Mr. Daniel] was prejudiced by the acts or omissions, i.e., facts indicating that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. A bare allegation that prejudice occurred without specific facts indicating how the petitioner was prejudiced is not sufficient. Daniel II, 86 So.3d at 416 (alteration adopted and citations omitted) (quoting Hyde v. State, 950 So.2d 344, 356 (Ala.Crim.App.2006)). Further, this specificity requirement attached to each allegation in the petition regarding trial counsel’s deficient performance and the prejudice that flowed from it. Id.; see also Coral v. State, 900 So.2d 1274, 1284 (Ala.Crim.App. 2004), rev’d on other grounds, Ex parte Jenkins, 972 So.2d 159 (Ala.2005). A. DEFICIENT PERFORMANCE UNDER STRICKLAND To state a facially sufficient ineffective assistance of counsel claim, Mr. Daniel must show both that his trial counsel’s performance was deficient and that he was prejudiced as a result. Strickland, 466 U.S. at 687, 104 S.Ct. at 2064. For the deficient performance prong, Mr. Daniel must demonstrate that trial “counsel’s representation fell below an objective standard of reasonableness.” Id. at 688, 104 S.Ct. at 2064. Reviewing courts apply a “strong presumption” that counsel’s representation was “within the wide range of reasonable professional assistance; that is, the defendant must overcome the presumption that, under the circumstances, the challenged action might be considered sound trial strategy.” Id. at 689, 104 S.Ct. at 2065 (quotation omitted). When this presumption is combined with § 2254(d), the result is double deference to the state court ruling on counsel’s performance. See Richter, 562 U.S. at 105, 131 S.Ct. at 788. And in any event, it is well established that “strategic choices made [by trial counsel] after thorough investigation of law and facts relevant to plausible options are virtually unchallengeable; [but] strategic choices made after less than complete investigation are reasonable precisely to the extent that reasonable professional judgments support the limitations on investigation.” Strickland, 466 U.S. at 690-91, 104 S.Ct. at 2066. This means “counsel has a duty to make reasonable investigations or to make a reasonable decision that makes particular investigations unnecessary.” Id. at 691, 104 S.Ct. at 2066. In the capital sentencing context, the Eighth and Fourteenth Amendments require “individualized consideration of mitigating factors.” Lockett v. Ohio, 438 U.S. 586, 606, 98 S.Ct. 2954, 2965, 57 L.Ed.2d 973 (1978). To give effect to this rule, “it is unquestioned that under the prevailing professional norms at the time of [Mr. Daniel’s 2003] trial, counsel had an ‘obligation to conduct a thorough investigation of the defendant’s background.’” Porter, 558 U.S. at 39, 130 S.Ct. at 452 (quoting Williams, 529 U.S. at 396, 120 S.Ct. at 1515); accord Rompilla, 545 U.S. at 385-86, 125 S.Ct. at 2465. When assessing the reasonableness of an attorney’s performance, the Supreme Court has looked to standards promulgated by the American Bar Association (ABA) as appropriate guides. See Wiggins, 539 U.S. at 524, 123 S.Ct. at 2536-37; see also Van Hook, 558 U.S. at 7-8, 130 S.Ct. at 17 (recognizing that in 1985, the ABA standards — which we can look to as “guides” — provided that “[information concerning the defendant’s background, education, employment record, mental and emotional stability, family relationships, and the like, will be relevant [to a mitigation investigation], as will mitigating circumstances surrounding the commission of the offense itself’ (alteration in original)); Rompilla, 545 U.S. at 387, 125 S.Ct. at 2465-66; Williams, 529 U.S. at 396, 120 S.Ct. at 1514-15. In Wiggins, for example, the Supreme Court noted the 1989 “ABA Guidelines provide that investigations into mitigating evidence ‘should comprise efforts to discover all reasonably available mitigating evidence and evidence to rebut any aggravating evidence that may be introduced by the prosecutor.’ ” 539 U.S. at 524,123 S.Ct. at 2537 (emphasis omitted) (quoting ABA Guidelines for the Appointment and Performance of Counsel in Death Penalty Cases, Guideline 11.4.1(C) (1989)). 1. The Sufficiency of Mr. Daniel’s Second Amended Rule 32 Petition Allegations Regarding Counsel’s Deficient Performance Mr. Daniel’s second amended Rule 32 petition pleaded more than sufficient specific facts about trial counsel’s acts and omissions to show their penalty phase investigation “fell below an objective standard of reasonableness.” Strickland, 466 U.S. at 688, 104 S.Ct. at 2064. For starters, Mr. Daniel pleaded that trial counsel had almost no meaningful contact with him or his family prior to trial. Specifically, he pleaded that “[t]rial [c]ounsel first met [him] at the preliminary hearing for his capital case in October of 2001. The next time [t]rial [c]ounsel spoke to Mr. Daniel was sixteen months later — just three days before the commencement of Mr. Daniel’s capital trial.” During the sixteen months Mr. Daniel was waiting for his trial, he wrote letters to trial counsel seeking to meet with them about his case. “Trial [c]ounsel simply ignored his request for a meeting.” Concerned, about having such little contact with his trial counsel, Mr. Daniel wrote the Alabama Bar Association before his trial to lodge a complaint against trial Counsel. Then when trial counsel did eventually meet with Mr. Daniel, rather than “focusing on the information about his case that Mr. Daniel was attempting to relay, [trial counsel] Mr. Hughes was far more interested in discussing Mr. Daniel’s complaint to the Alabama Bar Association.” Mr. Daniel also pleaded that his family fared no better in their attempts to communicate with trial counsel and as a result, “[t]rial [c]ounsel never interviewed in any meaningful way any members of [his] immediate family.” Specifically, Mr. Daniel pleaded that trial counsel ignored numerous efforts by his mother and sister to provide relevant background information: 46. Carolyn Daniel, Mr. Daniel’s mother, made a series of attempts to contact Mr. Hughes by phone and left several messages at his office. When Mr. Hughes finally returned one of those messages, he gave her no more than twenty minutes of his time and expressed no interest in meeting her or having further discussions. The extent of [t]rial [c]ounsel’s pretrial communications with Mr. Daniel’s mother was one brief telephone call. 47. Had [t]rial [e]ounsel had even a five minute conversation of substance with Mrs. Daniel, it is likely that they would have discovered facts about Mr. Daniel’s tragic childhood, including that when Mr. Daniel was just 3 years old he was present when his mother shot and killed his biological father ... and that his stepfather emotionally, physically, and sexually abused Mr. Daniel including forcing him to engage in sex acts with his two older sisters when Mr. Daniel was less than ten years old. 48. Tammi Daniel, Mr. Daniel’s sister, also attempted to contact [t]rial [c]oun-sel by telephone on a number of occasions before her brother’s trial. After Mr. Hughes failed to return a single one of her calls, she took matters in her own hands and drove all the way from Atlanta to Birmingham to speak to Mr.Hughes in person. He was unavailable. 49. Despite Tammi’s demonstrated willingness to assist in her brother’s defense, Mr. Hughes spoke with Tammi for less time than he spoke to her mother in the sixteen months leading up to trial. Ms. Haskins never spoke with her. In the one or two abbreviated conversations that they had, Mr. Hughes never asked Ms. Daniel about ... her family background, Mr. Daniel’s character, or her opinion of Mr. Daniel’s guilt. Nor did he seek her assistance in contacting any other family members. Had Mr. Hughes engaged in a meaningful conversation with Mrs. Daniel he would have learned about Mr. Daniel’s past. (Emphasis added.) Although there is no required number of meetings a trial attorney must have with his client and family members before trial, trial counsel’s failure to conduct any timely and meaningful mitigation interviews with Mr. Daniel and his family was objectively unreasonable under the circumstances of this case. We easily conclude that no competent attorney in 2003 would have failed to conduct timely and thorough background interviews with the defendant and his immediate family members when they were ready, willing, and available to speak with trial counsel and even contacted counsel on their own. a. Investigation of Conditions of Childhood Our conclusion is supported by Mr. Daniel’s second amended Rule 32 petition, which specifically detailed the chronic physical, emotional, and sexual abuse that the jury never heard, and that trial counsel could have gotten from timely and meaningful interviews of Mr. Daniel, his mother, or sister. For example: 120. Mr. Daniel’s mother married Ernest Western, a former Green Beret, when Mr. Daniel was seven years old. The couple lived together for the next 4 years. Mr. Daniel and his two sisters, along with Mr. Western’s two children, also lived in the house. During that time, Mr. Western terrorized all members of the Daniel household.[] He frequently walked around the house carrying a gun and wearing a sash of bullets. In front of the children, Mr. Western regularly beat Mrs. Daniel and threatened her with various forms of torture — including burning her hands in the fireplace. 121. Mr. Western “physically abused [Mr. Daniel] at least twice a week during the time that Mr. Western lived in the home.” The sole instance of such abuse that [t]rial [cjounsel introduced to the jury was the time when Mr. Western beat Mr.- Daniel (then barely 10 years old) so severely that Mr. Daniel’s kidney ruptured, which resulted in Mr. Daniel being hospitalized and subsequently removed from the family home. But there were many, many other beatings. 122. Information about the true extent of the physical abuse Mr. Western heaped on the Daniel children, and Mr. Daniel in particular, was readily available to [t]rial [c]ounsel from Mr. Daniel himself and Mr. Daniel’s older sister, Tammi. Had [t]rial [c]ounsel asked either of them about Mr. Western’s physical abuse of Mr. Daniel, he would have learned that Mr. Western beat Mr. Daniel regularly and far more severely than any of the other children in the household. Such information easily could and should have been introduced to the jury. 123. In addition to routinely administering extremely physical violent beatings, “[o]n almost a daily basis, [Mr. Daniel .and his sisters] were forced downstairs to the basement late at night to perform sexual acts on each other while Mr. Western watched. Mr. Western would then engage in sexual acts with all three of the children.” 124. Each of the Daniel children lived in fear of Mr. Western as a result of the violent sexual assaults they suffered at his hands. At night, the children tried not to get up to go to the bathroom because when they did, Mr. Western would grab them and molest them. During the winter months, the children huddled outside their house in the cold because they did not want to be alone in the house with Mr. Western while their mother was at work. 125. During the years that Mr. Western terrorized the Daniel children, Mr. Daniel would grab on to his mother’s leg screaming and crying and try to prevent her from leaving the family home. (Quoting neuropsychological report attached to petition.) This record includes no indication that a reasonable attorney would have had any reason to believe that conducting meaningful and timely interviews of Mr. Daniel, his mother, and sister Tammi would have been fruitless, counterproductive, or inconsistent with the evidence counsel did present at the penalty phase. Beyond our decision that Mr. Daniel pleaded sufficient facts to show counsel’s background investigation was deficient, we also conclude that the information uncovered by trial counsel in their cursory investigation would have led a reasonable attorney to investigate further. See Wiggins, 539 U.S. at 527, 123 S.Ct. at 2538. For example, trial counsel failed to follow up on critical information they learned in their brief conversation with Mr. Daniel’s mother. On the first day of trial, trial counsel moved for a psychiatric evaluation of Mr. Daniel and advised the trial court that Mr. Daniel’s' mother told them he suffered from attention deficit disorder, only went to the tenth grade in school, and “always had problems learning, adjusting and those kind of problems.” Further, counsel told the trial court: Even when [Mr. Daniel] was in school, he did not do a lot as far as academic achievement. And it was my understanding that they attempted to get him help while he was there. And the other thing, Judge, that came to our attention is that while he was in school, he had such a degree of problems that he was placed in the foster care system to try to correct some of his behavior.[] Information about Mr. Daniel’s “problems learning” and the fact his family “attempted to get him help” should have been red flags to trial counsel, alerting them to the need for more investigation. See Rompilla, 545 U.S. at 392, 125 S.Ct. at 2468-69; see also Wiggins, 539 U.S. at 525, 123 S.Ct. at 2537 (holding the “scope” of trial counsel’s “investigation was also unreasonable in light of what counsel actually discovered”). Yet trial counsel did not take the simple step of getting Mr. Daniel’s school records. Although in some instances “searching for old records can promise less than looking for a needle in a haystack,” this is not such a case. Rompilla, 545 U.S. at 389, 125 S.Ct. at 2467. To begin, Mr. Daniel’s school records should have been easy to get. Mr. Daniel went to school in Birmingham for some years, and this is where his trial took place. Also, in light of the information that Mrs. Daniel provided trial counsel about Mr. Daniel’s educational background, any reasonable investigation would have included an examination of his school records. Mr. Daniel’s second amended Rule 32 petition pleaded that counsel “would have been able to show the jury that Mr. Daniel’s cognitive difficulties extended far beyond” ADHD and dyslexia had trial counsel obtained Mr. Daniel’s school records. Beyond that, Mr. Daniel pleaded his school records revealed: 132.When Mr. Daniel was thirteen years old, he was referred to the Department of Student Services of the Birmingham Public School system to determine how best to educate him. Prior to this time, Mr. Daniel had been placed in special classes, transferred back into regular classes and re-enrolled in special classes after it became apparent that he could not keep up with his peers. According to the assessment made by the Guidance Department of the Birmingham Public School system ..., Mr. Daniel’s school referred him to the Department of Student Services for the following reasons: Renard has poor reading and mathematics skills. Behavioral observations made by the teacher suggest that he is distractible, disruptive, over-active, and exhibits bizarre behavior (laughs for no reason). Information received from the school indicates that Re-nard’s learning difficulty is being addressed via Basic Skills services. It is also indicated that he has been placed with another teacher but no improvement has been evidenced. 133. A test administered to assess his academic achievement revealed that Mr. Daniel’s reading comprehension was that of a student at the beginning of second grade and “severely deficient.” The test further revealed that Mr. Daniel’s mathematical ability was at also at a second grade level and also “severely deficient.” Finally, the test indicated that Mr. Daniel’s written language skills were at a high first grade level and “severely deficient” for his grade.... 134. The psychological evaluation prepared by the Birmingham Public Schools Guidance Department concluded that Mr. Daniel appeared to be “experiencing nonverbal and verbal comprehension difficulties,” and that he might “learn verbal skills at a much slower rate and retain less knowledge than the average child.” 135. The Guidance Department assessment further reveals that Mr. Daniel’s results on an intelligence test administered by the Public School system when Mr. Daniel was in sixth grade indicated that he was within the “[bjorderline classification of intelligence.” 140. While he was in the sixth grade in 1988, Mr. Daniel’s intellectual functioning was assessed according to the Wech-sler Intelligence Scale for Children— Revised (the “WISC-R”) and the Slos-son Intelligence Test. Mr. Daniel’s IQ was measured at 77 on the WISC-R and 70 on the Slosson Intelligence Test. (Internal citations omitted.) We conclude that Mr. Daniel pleaded sufficient facts in his second amended Rule 32 petition to show that trial counsel’s failure to obtain his school records was deficient under the totality of circumstances of his case and under prevailing professional norms. Mr. Daniel’s trial counsel, like the trial counsel in Wiggins, “abandoned their investigation of [Mr. Daniel’s] background after having acquired only rudimentary knowledge of his history from a narrow set of sources,” thereby making the investigation itself unreasonable. 539 U.S. at 524, 123 S.Ct. at 2537; see also Williams, 529 U.S. at 369, 395, 120 S.Ct. at 1500, 1514; Cooper v. Sec’y, Dep’t of Corr., 646 F.3d 1328, 1351-52 (11th Cir.2011) (finding deficient performance based on inadequate investigation where trial counsel interviewed the defendant, his mother, and a clinical psychologist, but not others). Because Mr. Daniel’s trial counsel failed to conduct a minimally adequate mitigation investigation, they “were not in a position to make a reasonable strategic choice as to whether” to conduct further investigation, Wiggins, 539 U.S. at 536, 123 S.Ct. at 2543, or to conclude that further investigation “would be fruitless or even harmful.” Strickland, 466 U.S. at 691, 104 S.Ct. at 2066. It is important to Mr. Daniel’s case that this record includes nothing to indicate that trial counsel’s limited investigation into Mr. Daniel’s troubled family background was the product of reasonable professional judgment. See Burger v. Kemp, 483 U.S. 776, 794-95, 107 S.Ct. 3114, 3126, 97 L.Ed.2d 638 (1987). To the contrary, during oral argument in this Court, the state confirmed that there was no evidence or indication in this record “that trial counsel uncovered in their investigation something that would make them not want to go forward, that might be unhelpful or counterproductive.” In summary, Mr. Daniel pleaded sufficient facts to overcome the presumption that trial counsel’s inactivity in this ease was strategically defensible based on the totality of the state court record. Our conclusion that Mr. Daniel’s second amended Rule 32 petition pleaded sufficient facts to show that trial counsel failed to conduct a minimally adequate mitigation investigation implicates counsel’s deficient performance with respect to all aspects of counsel’s investigation, development, and presentation of Mr. Daniel’s penalty phase defense. For example, because trial counsel failed to get Mr. Daniel’s school records or otherwise follow up on the information they learned from Mrs. Daniel, it is not surprising that trial counsel was not able to give the trial court relevant and necessary information to support their motion for a mental health evaluation. This was the motion made by trial counsel on the first day of Mr. Daniel’s trial. On this record, we conclude that Mr. Daniel’s second amended Rule 32 petition pleaded sufficient facts to show trial counsel performed deficiently in failing to secure the assistance of a mental health expert to assist with Mr. Daniel’s defense during the penalty phase. In fact, after reviewing the results of intelligence testing performed on Mr. Daniel in his school records, postconviction counsel hired Drs. Daniel Marson and Kristen Triebel (both affiliated with the University of Alabama at Birmingham) to prepare a neuropsychological assessment of Mr. Daniel. Mr. Daniel attached the neuropsychological report of Drs. Marson and Triebel to his second amended Rule 32 petition and affirmatively pleaded that both doctors “live in Alabama and would have been available to testify at Mr. Daniel’s trial.” This report concluded, among other things: that Mr. Daniel’s “[historical and current intelligence testing were most consistent with borderline intellectual functioning”; that he likely suffered from “childhood dissociative disorder with psychotic features” as a result of daily sexual, physical, and emotional abuse; that he has “[significant impairments in adaptive functioning both prior to and after age 18”; that he has “[c]urrent cognitive deficits in verbal memory, auditory working memory, and executive function”; and that he likely “suffered from depression since childhood.” After reviewing Mr. Daniel’s school records, a reasonable attorney would have discovered the results of Mr. Daniel’s childhood intelligence testing. Armed with this evidence, a reasonable attorney would have been prompted to further investigate the extent of Mr. Daniel’s cognitive impairments. A proper inquiry would not have been limited to whether Mr. Daniel was intellectually disabled under Atkins v. Virginia, 536 U.S. 304, 122 S.Ct. 2242, 153 L.Ed.2d 335 (2002), but would have looked to whether he is borderline intellectually disabled, as his school records indicate. That’s because borderline intellectual disability that does not rise to the level of intellectual disability under Atkins is still itself powerful mitigation. See Williams, 529 U.S. at 398, 120 S.Ct. at 1515 (“[T]he reality that [Mr. Williams] was ‘borderline mentally retarded,’ might well have influenced the jury’s appraisal of his moral culpability.”); Wiggins, 539 U.S. at 535, 123 S.Ct. at 2542 (noting that “diminished mental capacities” is among “the kind of troubled history ... relevant to assessing a defendant’s moral culpability”). Considering that “[t]he intellectual-disability determination is fact-intensive, requiring careful consideration of the petitioner’s intellectual functioning, adaptive skills, and age of onset, with the assistance of qualified experts,” Conner v. GDCP Warden, 784 F.3d 752, 766 (11th Cir.2015), a reasonable attorney in 2003 would have at least asked for the appointment of qualified experts to explore Mr. Daniel’s borderline intellectual disability. Mr. Daniel’s trial counsel did not. And there is nothing in the record to refute that trial counsel could have retained Dr. Marsons or Dr. Triebel, or others with their expertise, to investigate and develop relevant and admissible mitigating evidence about Mr. Daniel’s borderline intellectual disability and other childhood difficulties. We conclude that Mr. Daniel pleaded sufficient facts in his second amended Rule 32 petition to show his trial counsel were deficient for not exploring his borderline intellectual disability. b. Investigation of Prior Burglary Conviction We have also reviewed the record regarding trial counsel’s failure to investigate and challenge the state’s characterization of Mr. Daniel’s prior burglary conviction as a violent felony involving attempted rape. Mr. Daniel’s second amended Rule 32 petition pleaded specific and sufficient facts to state a claim that trial counsel was deficient in that regard as well. During the penalty phase presentation to the jury, the state introduced documentary evidence that Mr. Daniel had a prior conviction for second degree burglary to prove the aggravating circumstance that he was previ-oúsly convicted of a felony involving the use or threat of violence. The state addressed the “nature” of Mr. Daniel’s second degree burglary during its closing argument, emphasizing to the jury that it “was a violent offense” that involved “entering or remaining in someone’s home for the purpose of committing rape.” Mr. Daniel’s second amended Rule 32 petition specifically alleged that “[tjrial [c]ounsel’s failure to investigate the circumstances surrounding [Mr. Daniel’s burglary] conviction left the jury with exactly the impression that the State wanted them to have” — “that Mr. Daniel was a habitually violent criminal, deserving of the death penalty.” In support, the Rule 32 petition alleged trial counsel “had statutory notice of the aggravating circumstances on which the State could rely.” The petition also pleaded that trial counsel had a “duty to investigate the circumstances of Mr. Daniel’s prior convictions that could be used as statutory aggravators under” Rompilla. Mr. Daniel alleged the records of his prior burglary conviction were “available in the same courthouse as his capital murder trial and ... even a cursory review of these records would have led [t]rial [c]ounsel to investigate the circumstances surrounding Mr. Daniel’s conviction.” Noting that government records describing his burglary conviction did not mention the word “rape,” Mr. Daniel alleged that “[t]rial [c]ounsel should have made some effort to discover how this element of the offense was added” to the indictment. It is a fact that the word “rape” , does not appear in the case action summary, complaining witness affidavit, or plea agreement that Mr. Daniel signed. Neither does the word “rape” appear in an August 1998 report of the Alabama Board of Pardons and Paroles that described the details underlying Mr. Daniel’s second degree burglary conviction, as the Rule 32 petition noted. Although the second amended Rule 32 petition acknowledged that trial counsel objected to the introduction of Mr. Daniel's burglary conviction, it described the following: [P]rior to the penalty phase, [tjrial [cjounsel had never even looked at Mr. Daniel’s record, much less prepared arguments that could be advanced to negate the impact of that record in the minds of the jury. Trial [cjounsel’s ignorance rendered it impossible for them to rebut effectively the State’s aggravation case because, at the time of trial, [tjrial [cjounsel was completely ignorant of the basis upon which that ease would be built. Besides the readily available legal records trial counsel failed to discover, the Rule 82 petition alleged trial counsel “neither sought nor discovered” other information that would have reduced the weight of the prior violent felony aggravator. Mr. Daniel alleged that trial counsel “did not make any effort to speak to Bonnie Stevenson, the complaining witness in the second degree burglary charge.” According to an interview of Ms. Stevenson conducted by postconviction counsel, “Mr. Daniel never even came close to physically or sexually assaulting her or any other member of her family.... To the contrary, for the duration of the incident, Mr. Daniel was standing outside a barred window and had no ability to access the apartment.” Finally, Mr. Daniel alleged that had trial counsel been aware of his guilty plea, “which they clearly were not,” they would have been able to contact Cassandra Golden, the attorney who represented him in his prior burglary conviction. The Rule 32 petition alleged that postconviction counsel interviewed Ms. Golden about the circumstances surrounding Mr. Daniel’s plea and was told “that Mr. Daniel’s plea did not involve any charge of attempted rape.” Indeed, Mr. Daniel specifically pleaded that his signed plea agreement “evince[d] his understanding [Jhe had been indicted for distribution of a controlled substance, burglary and ‘RSP’ — not attempted rape.” The facts that Mr. Daniel alleged in his second amended Rule 32 petition were specific and sufficient to state a claim that, based on the totality of circumstances of his case, his trial counsel was deficient for failing to investigate and challenge the state’s reliance on his second degree burglary conviction. It is well established that counsel “ha[sj a duty to make all reasonable efforts to learn what they [can] about [prior offenses]” upon which counsel knows the prosecution intends to rely in seeking the death penalty. Rompilla, 545 U.S. at 385-86, 125 S.Ct. at 2465. This includes “obtaining the [state’s] own readily available file on the prior conviction to learn what the [state] knew about the crime, to discover any mitigating evidence the [state] would downplay, and to antiei-pate the details of the aggravating evidence the [state] would emphasize.” Id. Trial counsel’s “obligation to rebut aggravating evidence extended beyond arguing it ought to be kept out.” Id. at 386 n. 5,125 S.Ct. at 2465 n. 5. In Rompilla, the Supreme Court held that trial counsel’s failure to investigate the circumstances of the defendant’s prior conviction “fell below the level of reasonable performance” because trial counsel knew that the Commonwealth would use the defendant’s prior conviction for rape and assault to establish Mr. Rom-pilla’s history of violent felonies and it was “undisputed that the prior conviction file was a public document, readily available for the asking at the very courthouse where Rompilla was to be tried.” Id. at 383-84,125 S.Ct. at 2464. Accepting Mr. Daniel’s allegations as true — as Alabama courts do at the pleading stage — trial counsel unreasonably failed to inquire into the circumstances surrounding Mr. Daniel’s prior second degree burglary conviction. This despite the fact that trial counsel was on notice that the state intended to argue that the burglary conviction established an aggravating factor as a violent felony involving attempted rape, and that the records were readily available in the same courthouse where the capital trial took place. Had trial counsel made even a cursory review of government documents, they could have informed the jury that the record of Mr. Daniel’s burglary conviction included no evidence that he ever came close to physically or sexually assaulting anyone. 2. The Unreasonableness of the State Court’s Decision about Deficient Performance In concluding that Mr. Daniel failed to plead his penalty phase ineffective assistance -claim with sufficient specificity, the Alabama Court of Criminal Appeals primarily focused on Mr. Daniel’s failure to plead “how he was prejudiced by counsel’s failure to present evidence.” See Daniel II, 86 So.3d at 429. The Court of Criminal Appeals did not address whether trial counsel’s investigation into his background was reasonable under prevailing professional norms. On this point, what we said in Williams v. Allen, 542 F.3d 1326 (11th Cir.2008), is equally true here: The court appears to have assumed, based on the fact that [Mr. Daniel’s] sentencing phase presentation included some evidence of abuse, that counsel’s investigation was sufficient to permit a reasonable decision as to what evidence should be offered. However, “[i]n assessing the reasonableness of an attorney’s investigation, ... a court must consider not only the quantum of evidence already known to counsel,- but also whether the known evidence would lead a reasonable attorney to investigate further.” Wiggins, 539 U.S. at 527, 123 S.Ct. at 2538. As discussed above, we conclude that trial counsel abandoned their investigation at an unreasonable point, particularly in light of the information about [Mr. Daniel’s] background that the investigation revealed.- By simply assuming that trial counsel’s investigation was adequate, without considering the reasonableness of counsel’s decision to limit the scope of their inquiry, the Alabama court unreasonably applied Strickland. See id. at 527-28, 123 S.Ct. at 2538. Id. at 1341 (some citations omitted). We further conclude that the Alabama Court of Criminal Appeals unreasonably applied clearly established Supreme Court precedent when it concluded that Mr. “Daniel failed to plead sufficient facts to support a Rompilla claim.” Daniel II, 86 So.3d at 440. In rejecting this claim, the Court of Criminal Appeals acknowledged that “Rompilla held that it was ineffective assistance of counsel for counsel at the penalty phase of Rompilla’s capital trial to not investigate his prior conviction the State of Pennsylvania intended to rely on at the sentencing hearing.” Id. at 439. But the Court of Criminal Appeals distinguished Rompilla, saying “the file of Rompilla’s prior conviction contained a veritable cornucopia of potential mitigating evidence concerning Rompilla’s childhood and mental illness.” Id: Because Mr. Daniel did not plead “such information existed” in the file of his prior conviction, the Court of Criminal Appeals held he failed to sufficiently plead a Rompilla claim. Id. at 439-40. The Court of Criminal Appeals also said the state did not emphasize the prior conviction and found that “counsel could have made a strategic decision to not call further attention to that conviction by introducing specific details about the attempted burglary conviction.” Id. at 439. This reasoning is contrary to or an unreasonable application of clearly established federal law. Rompilla did not hold that prior conviction records must contain mitigating evidence in order to trigger counsel’s duty to consult them. Rather, it held that counsel renders deficient performance if he fails to investigate readily available records, when he is on notice that the state intends to rely on prior convictions as aggravation. Rompilla, 545 U.S. at 385-86, 389, 125 S.Ct. at 2465, 2467 (“It flouts prudence to deny that a defense lawyer should try to look at a file he knows the prosecution will cull for aggravating evidence, let alone when the file is sitting in the trial courthouse, open for the asking.”); see also id. at 387, 125 S.Ct. at 2465 (“The notion that defense counsel must obtain information that the State has and will use against the defendant is not simply a matter of common sense.”). Defense counsel must be prepared to respond to the state’s case in aggravation. Id. at 385, 125 S.Ct. at 2465 (“With every effort to view the facts as a defense lawyer would have done at the time, it is difficult to see how counsel could have failed to realize that without examining the readily available file they were seriously compromising their opportunity to respond to a case for aggravation.”). And in any event, a finding that the state did not emphasize the prior conviction is unreasonable based on Mr. Daniel’s state court record in three ways. First, it ignores that documentary exhibits related to the burglary conviction were the only new evidence introduced by the state during the penalty phase. Second, it ignores-that the state’s closing argument stressed that Mr. Daniel had three aggravating circumstances, including “entering or remaining in someone’s home for the purpose of committing rape.” Third, that the state may not have presented any evidence about the details of his prior