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Maples v. Thomas

Summarized by: 

Date Filed: October 4, 2011
Case #: 10-63
Court Below: 586 F.3d 879 (11th Cir. 2009)
Full Text Opinion: http://sblog.s3.amazonaws.com/wp-content/uploads/2011/02/02-18-Golan-Opinion-below.pdf

Criminal Procedure: Whether there is “cause” to excuse a procedural default where petitioner is blameless for the default, the state's own conduct contributed to the default, and petitioner's attorneys of record were no longer functioning as his agents at the time of any default.

Maples was convicted of capital murder and sentenced to death in Alabama. On August 1, 2001, Maples filed a petition for post-conviction relief with the help of two attorneys in a New York law firm. Eighteen months later, the Alabama trial court denied the petition. When the court, however, sent copies of rulings to Maple’s attorneys, the firm’s mailroom returned the mail unopened. Maples’ attorneys had left their original law firm without notifying the court. When the court’s clerk received the returned unopened mail, the clerk did nothing and Maples missed his opportunity to file an appeal on the denial of his petition.

The District Court held that Maples could not show "cause" to overcome a procedural default on the grounds that attorney performance does not constitute "cause" to excuse a default. The Eleventh Circuit affirmed the District Court. On appeal, Maples argues that a writ of habeas corpus is governed by equitable discretion, thus, the court should find “cause” to excuse a procedural default that occurred due to no fault of the petitioner.