Another SCOTUS case to deal with (collateral) Blakely concerns?

A crackerjack reader has brought to my attention the fact that, in the Supreme Court’s grant of cert. last week in Halbert v. Michigan, 03-10198 (available here), the second question presented could be of significance in the post-Blakely world.  Here is the question in full form:

Is Petitioner entitled to resentencing, where counsel failed to render effective assistance by not objecting to improper scoring under Michigan’s sentencing guidelines which resulted in Petitioner receiving a considerably longer sentence?

Though, obviously, this question does not directly confront Blakely issues, any further elaboration on the meaning and application of ineffective assistance in the context of (noncapital) sentencing representation could be of great import in the wake of Blakely.  The Supreme Court’s discussion of these matters in Glover v United States, 531 US 198 (2001), set out only the most basic of considerations.

(And yet, as suggested by Jonathan Soglin at Criminal Appeal in this post, it is not clear that the ineffectiveness question in Halbert v. Michigan is of real concern to the High Court.  As detailed by SCOTUSblog in this post, the Court clearly took Halbert to address “the constitutionality of a Michigan procedure that denies a free lawyer to aid an individual who has pleaded guilty but who wants to seek a discretionary appeal in a higher court.”   The Court sought to confront that issue earlier this Term in Kowalski v. Judicial Circuit Court (03-407), but a standing problem got in its way.)