Dist. Ct. did not err in denying defendant’s habeas petition, challenging his drug convictions on ground that record failed to show that he validly waived his appointed appellate counsel on direct appeal. State court’s determination that valid waiver had occurred was not unreasonable application of established law, where: (1) record need only show existence of “straightforward assent” for waiver of appellate counsel, as opposed to colloquy that is normally required for waiver of trial counsel; and (2) record showed that defendant told his appellate counsel that he wanted to proceed pro se, and defendant subsequently signed waiver form provided by appellate counsel that informed defendant of perils of proceeding pro se. Ct. rejected defendant’s argument that instant waiver was nonetheless involuntary due to his inability to read and write and due to his prior vacillation on whether to proceed pro se, since: (1) written waiver came after any oral vacillation on waiver of appellate counsel; and (2) state court could reasonably discount evidence of defendant’s inability to read or write.