In Breard v. Greene, 523 U.S. 371, 373, 118 S. Ct. 1352, 1353-54, 140 L. Ed. 2d 529, 536 (1998), the defendant, a Paraguayan national, brought a habeas corpus petition alleging that state officials had violated the Convention by failing to notify the Paraguayan consulate of his arrest for rape and capital murder. The Supreme Court recognized that the Convention "arguably confers on an individual the right to consular assistance following arrest" but also noted that in 1996, prior to defendant's filing his claim, Congress had enacted the Antiterrorism and Effective Death Penalty Act, 28 U.S.C.A. 2254(a), (e)(2) (Supp.1999), which provided that a habeas petitioner alleging that he is held in violation of treaties of the United States will not be afforded an evidentiary hearing if defendant failed to develop the factual basis of his claim in the state court proceeding. Id. at 376, 118 S. Ct. at 1355, 140 L. Ed. 2d at 538. Because defendant failed to make such a showing, his claim was barred. Id. at 377, 118 S. Ct. at 1355, 140 L. Ed. 2d at 538. The Supreme Court observed that even if defendant's Convention claim were properly raised and proven, "it is extremely doubtful that the violation should result in the overturning of a final judgment of conviction without some showing that the violation had an effect on the trial." Ibid.