Willamette Law Online

United States Supreme Court


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Trevino v. Thaler

Summarized by: 

Date Filed: May 28, 2013
Case #: 11-10189
Breyer, J., delivered the opinion for the court, in which Kennedy, Ginsburg, Sotomayor, and Kagan, JJ., joined. Roberts, C. J., filed a dissenting opinion, in which Alito, J., joined. Scalia, J., filed a dissenting opinion, in which Thomas, J., joined.
Full Text Opinion: http://www.supremecourt.gov/opinions/12pdf/11-10189_6k47.pdf

Habeas Corpus: The "good cause" exception recognized in Martinez v. Ryan applies if a state's procedural framework limits any meaningful opportunity to raise a claim on direct appeal that trial counsel provided ineffective assistance.

Petitioner sought a writ of habeas corpus. Federal counsel raised a claim of ineffective assistance of counsel at the trial level, and the case was remanded. Texas state review barred the claim under procedural default because Petitioner’s state counsel did not raise the claim during the initial collateral review. The District Court denied granting the writ, and the Fifth Circuit affirmed because Texas procedures do not require such claims to be raised upon collateral review.


 Petitioner appealed to the Supreme Court which granted certiorari to determine whether the “good cause” exception recognized in Martinez v. Ryan, 566 U. S. 1 (2012), applies to Texas. The Court vacated, remanded and held that while Texas seemingly permits ineffective assistance claims to be raised upon direct review, raising such claims is “virtually impossible.” Texas effectively bars any meaningful review of claims of ineffective assistance of counsel. The Court applied the "good cause" exception to Texas in order to give a meaningful opportunity to raise a claim on direct appeal that trial counsel provided ineffective assistance.