Martinez v. Ryan

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Habeas Corpus
  • Date Filed: March 20, 2012
  • Case #: 10-1001
  • Judge(s)/Court Below: Kennedy, J., delivered the opinion of the Court, in which Roberts C.J., and Ginsburg, Breyer, Alito, Sotomayor and Kagan, JJ., joined. Scalia J., filed a dissenting opinion, in which Thomas, J., joined.
  • Full Text Opinion

A federal habeas court may excuse a procedural default of an ineffective-assistance of counsel claim when the claim was not properly presented in state court due to an attorney’s errors in an initial-review collateral proceeding.

In Arizona, a prisoner may only bring a claim for ineffective assistance of counsel in an initial-review collateral proceeding, not on direct review. Petitioner, an Arizona state prisoner, sought post-conviction relief in state court, but his post-conviction counsel failed to raise an ineffective-assistance claim during the first collateral proceeding which resulted in a procedural default barring federal habeas review. After obtaining new counsel, Petitioner filed a petition for a writ of habeas corpus in federal court arguing ineffective assistance of counsel at trial and during the first phase of his state collateral proceedings. Petitioner also argued that he had a constitutional right to effective counsel at the first stage of a collateral proceedings. The district court denied his petition and the Court of Appeals for the Ninth Circuit affirmed, citing Coleman v. Thompson, 501 U.S. 722 (1991) that there is no constitutional right to counsel in collateral proceedings.

On review, the Supreme Court declined to address the issue on constitutional grounds. Instead it created a narrow exception to Coleman that a procedural default does not bar federal habeas review in an initial-review collateral proceeding since the state trial court decides the claim’s merits before another court has addressed the claim, and that if undertaken with ineffective counsel, the proceeding “may not be sufficient to ensure that proper consideration was given to the substantive claim.”

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