While Mike was arguing this morning before the U.S. Supreme Court, Transcript of Oral Argument, Walker v. Martin, 09-996, the Ninth Circuit reversed the Sacramento district court's denial of habeas corpus in another of his appeals, finding that state court trial counsel rendered ineffective assistance by failing to ask that evidence of the victim's DNA be tested before trial. See Diaz v. Clark, 08-15808. It's an unpublished, 2-1, decision.
[1/28/12 Update: The Supreme Court reversed in Walker v Martin and the Diaz decision did not last as the Ninth Circuit reversed course on remand from the Supreme Court. See my 1/28/12 post ].