JENNIFER WALKER ELROD, Circuit Judge:

Ray Charles Miller ("Miller") appeals the district court's denial of his 28 U.S.C. § 2254 application challenging his guilty-plea conviction for intoxicated manslaughter with a vehicle. We granted a certificate of appealability ("COA") on three issues: (1) whether Miller's trial counsel provided ineffective assistance regarding a lapsed plea offer from the State; (2) whether the trial court violated Miller's right to self-representation by denying his request to proceed pro se; and (3) whether Miller's trial counsel provided ineffective assistance because he refused to move to withdraw or had a conflict of interest. We AFFIRM.

I.

In March 2007, a Texas grand jury indicted Miller for intoxicated manslaughter with a vehicle.1 On the day before jury selection for Miller's trial, the State offered Miller a plea bargain with a recommended sentence of 16 years of imprisonment. Miller's trial counsel, Scott E. Scammahorn ("Scammahorn"), described his communications with Miller regarding the 16-year offer:

Miller tells a different story. According to Miller, Scammahorn failed to relay the prosecutor's response to the counteroffer in a timely manner, and this delay effectively denied him the opportunity to accept the 16-year offer. There is some record support for Miller's version of events. At the pretrial hearing, Miller stated: "I asked Mr. Scammahorn to go back and see if he could get it a little lower, but get back with me that same day, so I could make a decision on it. I was willing to make a decision on [the prosecutor's] offer that day, but there was a misunderstanding between me and Mr. Scammahorn." Scammahorn explained that the miscommunication "could have been partially [his] fault." He told the court that Miller "did say go back to [the prosecutor], which I did, knowing the answer, and I didn't get back to him, because I knew the answer. But I didn't — I communicated to his wife and maybe that's where the miscommunication took place."

Considering this purported miscommunication and other issues between Miller and Scammahorn, Miller sought to proceed pro se. In a lengthy exchange, the trial court questioned Miller about his experience with the law and explained the dangers of self-representation. Although Miller remained steadfast in his request to proceed pro se, the court decided not to allow it, stating: "I don't believe you're qualified to represent yourself. I don't have a motion from Mr. Scammahorn to allow him to withdraw. But under the present state of the record, he is still your retained attorney, and that's the way the Court is going to leave it." The trial court explained that Miller could not use a last-minute request for self-representation to "manipulate the orderly administration of justice," adding "based on your answers to my questions and the fact that you've got retained counsel standing here, I'm simply not in a position to let you represent yourself."

The parties reached a plea agreement the following day, after jury selection was complete. The State agreed to recommend a sentence of 35 years of imprisonment in Miller's intoxicated manslaughter case and to dismiss a separate indictment against Miller for felony theft. In return, Miller agreed to plead guilty and to waive certain rights, including the right to appeal. Miller also pleaded true to having two prior state felony convictions, which exposed him to a statutory imprisonment range of 25 years to life as a habitual offender. Tex. Penal Code § 12.42(d). Pursuant to the plea agreement, Miller signed several written documents, including an Acknowledgment of Admonishments, as well as a Waiver of Trial by Jury and Waiver of Confrontation and Agreement to Stipulate.

Miller appealed his case to the state court of appeals, which dismissed his appeal based on the express appeal waiver contained in Miller's guilty plea agreement. Miller v. State, No. 12-08-00053-CR, 2009 WL 531528, at *1 (Tex.App.-Tyler 2009, pet. ref'd). The Texas Court of Criminal Appeals ("TCCA") refused a petition for discretionary review. Id.

Miller then filed a state habeas application claiming, inter alia, that his trial counsel provided ineffective assistance by failing to keep him informed of the status of the 16-year plea offer before it lapsed, and that the trial court and his trial counsel violated his right to self-representation. In its Findings of Fact and Suggested Conclusions, the state habeas court took judicial notice of all prior proceedings and entered findings of fact and conclusions of law, including:

A state appeals court affirmed, and the Texas Court of Criminal Appeals denied Miller's application without written order.

In his instant § 2254 application, Miller asserted the same claims raised in his state habeas application. The magistrate judge recommended denial of Miller's § 2254 application on the merits and the denial of a COA on the grounds that: (1) Miller waived his claims by pleading guilty, and (2) the claims failed on the merits. Over Miller's objections, the district court adopted the magistrate judge's report and recommendation, denied his § 2254 application, and denied a COA. Miller timely appealed the district court's judgment, and sought and obtained a COA on the three issues stated above.

II.

In reviewing a district court's decision on a § 2254 application, we review the district court's findings of fact for clear error and its conclusions of law de novo. Harrison v. Quarterman, 496 F.3d 419, 423 (5th Cir.2007). We must also consider the deferential standards of the Antiterrorism and Effective Death Penalty Act ("AEDPA"), which the district court applied in evaluating Miller's § 2254 claims. See id. Pursuant to AEDPA, we cannot grant federal habeas relief on claims adjudicated on the merits in state court unless the adjudication resulted in a decision that: (1) "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) "was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding." § 2254(d). Moreover, we presume the state court's factual findings to be correct unless the applicant rebuts the presumption by clear and convincing evidence. § 2254(e)(1).

Section 2254(d) sets forth a "highly deferential standard for evaluating state-court rulings, which demands that state-court decisions be given the benefit of the doubt." Pinholster, 131 S.Ct. at 1398 (internal quotation marks and citation omitted). To satisfy the standards of § 2254(d), a state prisoner must show that the state court's ruling on his claim "was so lacking in justification that there was an error well understood and comprehended in existing law beyond any possibility for fairminded disagreement." Harrington v. Richter, ___ U.S. ___, 131 S.Ct. 770, 786-87, 178 L.Ed.2d 624 (2011).

Having described the contours of AEDPA's highly deferential framework, we now turn to the three claims certified for appeal.2

A.

First, Miller claims that his trial counsel provided ineffective assistance in allowing the State's plea bargain offer to lapse.3 To prevail on a claim of ineffective assistance of counsel, the defendant must show that his "counsel's performance was deficient" and that "the deficient performance prejudiced the defense." Strickland v. Washington, 466 U.S. 668, 687, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984). To establish deficient performance, Miller "must show that counsel's representation fell below an objective standard of reasonableness." 466 U.S. at 688, 104 S.Ct. 2052. In evaluating deficiency, we apply a "strong presumption that counsel's conduct falls within the wide range of reasonable professional assistance." Id. at 689, 104 S.Ct. 2052. A failure to establish either deficient performance or prejudice defeats the ineffective-assistance-of-counsel claim. Id.

In the context of an ineffective-assistance-of-counsel claim subject to AEDPA deference, "the pivotal question is whether the state court's application of the Strickland standard was unreasonable." Richter, 131 S.Ct. at 785. While "[s]urmounting Strickland's high bar is never an easy task," "establishing that a state court's application of Strickland was unreasonable under § 2254(d) is all the more difficult." Id. at 788 (citations omitted). "[A] habeas court must determine what arguments or theories supported or, as here, could have supported, the state court's decision; and then it must ask whether it is possible fairminded jurists could disagree that those arguments or theories are inconsistent with the holding in a prior decision of [the Supreme] Court." Id. at 786. Put simply, both the Strickland standard and the AEDPA standard are "highly deferential" and "when the two apply in tandem, review is `doubly' so." Id. (citations omitted).

Here, Miller asserts that Scammahorn's communication failure regarding the 16-year plea offer constituted ineffective assistance of counsel. Specifically, Miller claims that Scammahorn never relayed the State's response to his 12-year counteroffer, and that he would have accepted the State's initial 16-year plea offer had he known that it was final. This claim implicates the Supreme Court's recent decision in Missouri v. Frye, which held that the Sixth Amendment right to effective assistance of counsel extends to plea negotiations. ___ U.S. ___, 132 S.Ct. 1399, 1408, 182 L.Ed.2d 379 (2012). In Frye, the court noted the general rule that defense counsel has a duty to communicate formal offers from the prosecution where the relevant terms and conditions may result in a lesser sentence, a conviction on lesser charges, or both. Id. We have previously held, and now reiterate, that Frye did not announce a new rule of constitutional law because it "merely applied the Sixth Amendment right to counsel to a specific factual context." In re King, 697 F.3d 1189, 1189 (5th Cir.2012). Therefore, we may consider Frye when determining whether the state habeas court's decision was "contrary to, or involved an unreasonable application of, clearly established Federal law." § 2254(d)(1).

The facts of this case, however, are readily distinguishable from Frye. Here, the state habeas court expressly found that "[n]othing in the record ... indicate[d] that counsel failed to convey any plea offers from the State." Compare Frye, 132 S.Ct. at 1410 ("On this record, it is evident that Frye's attorney did not make a meaningful attempt to inform the defendant of a written plea offer before the offer expired."). In reaching its conclusion, the state habeas court credited Scammahorn's affidavit, which indicated that he informed Miller of the State's 16-year offer and counteroffered with 12 years, as Miller instructed him to do. Scammahorn further stated that he met with Miller after the State rejected Miller's counteroffer, at which time Miller again said that he would not accept the State's initial 16-year offer. Miller has not, by clear and convincing evidence, rebutted the presumption of correctness owed to the state habeas court's factual determination. See Batchelor v. Cain, 682 F.3d 400, 405 (5th Cir.2012) (affirming that pursuant to AEDPA, "a determination of a factual issue made by a State court shall be presumed to be correct," and that presumption must be rebutted by "clear and convincing evidence") (quoting 28 U.S.C. § 2254(e)(1)); see also Richards v. Quarterman, 566 F.3d 553, 563 (5th Cir.2009) (affirming that "the state habeas court's factual determinations, including its credibility findings, are entitled to a presumption of correctness"). Thus, Miller's claim cannot survive under Strickland and AEDPA's combined, "doubly" deferential review. Richter, 131 S.Ct. at 786.4

B.

Second, Miller claims that the trial court violated his right to self-representation when it denied his request to proceed pro se at trial. A criminal defendant has a constitutional right to self-representation at trial when he knowingly and intelligently waives the right to counsel. Faretta v. California, 422 U.S. 806, 807, 835, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975). The defendant's waiver of his right to counsel must be unequivocal, and it should not be inferred by the court in the absence of a clear and knowing election. Brown v. Wainwright, 665 F.2d 607, 610 (5th Cir. 1982) (en banc). Before accepting a waiver of counsel, the court must consider and weigh:

McQueen v. Blackburn, 755 F.2d 1174, 1177 (5th Cir.1985).

The state habeas noted that it "conducted a serious and extensive inquiry into the defendant's claim of a conflict of interest and his desire to proceed pro se." It also made three factual determinations involving Miller's self-representation claim: (1) that Scammahorn continued to advocate successfully for Miller during the course of the proceedings without objection from Miller, even after the trial court denied Miller's motion to proceed pro se;5 (2) that "[t]he record indicates that the defendant was equivocal in his intent to fire his retained trial counsel where he asked counsel to continue to negotiate a plea agreement for him even after allegedly terminating his services"; and (3) that "[t]he Court did not err in refusing the allow the defendant to proceed pro se where no motion to withdraw was filed by the defendant's trial attorney."

Pursuant to AEDPA, these determinations of the state habeas court — which stress that Scammahorn successfully advocated for Miller during the course of his proceedings — are entitled to deference. See Batchelor, 682 F.3d at 405; Richards, 566 F.3d at 563. Miller has failed to demonstrate that the state habeas court's decision was contrary to, or an unreasonable application of, clearly established federal law, or that it was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding. § 2254(d). Accordingly, Miller is not entitled to habeas relief on his self-representation claim.

C.

Third, Miller claims that Scammahorn provided ineffective assistance regarding his right to self-representation on two grounds. First, Miller argues that Scammahorn refused to withdraw from the case after he expressed a clear and unequivocal wish to proceed pro se.6 Second, he contends that Scammahorn had a conflict of interest, and therefore, abdicated his duty of loyalty to Miller by refusing to withdraw from the case.

These challenges fail for the same reasons involving Miller's self-representation claim articulated above. Specifically, the state habeas court determined that Scammahorn advocated successfully for Miller throughout the proceedings and that Miller equivocated in his request to proceed pro se.7 This factual determination of the state habeas court is entitled to deference pursuant to AEDPA. See Batchelor, 682 F.3d at 405; Richards, 566 F.3d at 563. Because it is reasonable, we agree with the district court that Miller is not entitled to habeas relief on this claim.

III.

For the foregoing reasons, we AFFIRM the district court's denial of Miller's habeas petition.