March 20, 2012

Supreme Court Decides Martinez v. Ryan

On March 20, 2012, the U.S. Supreme Court decided Martinez v. Ryan, No. 10-1001, holding that a federal habeas court may excuse a procedural default on an ineffective-assistance-of-trial-counsel claim when state law requires that claim to be raised in a collateral proceedings and the claim was not preserved properly, but the prisoner had no or only ineffective counsel during the initial-review collateral proceeding.

Martinez, an Arizona prisoner, was convicted by a jury of two counts of sexual conduct with a minor. Under Arizona law, Martinez could not challenge the effectiveness of his trial counsel on direct appeal but was required to do so later in collateral proceedings. During the direct appeal, Martinez's attorney (a new one after trial) also initiated state collateral proceedings but did not raise a claim of ineffective assistance of trial counsel. Martinez's conviction was affirmed by the Arizona Court of Appeals, and the Arizona Supreme Court denied review. The post-conviction action was ultimately dismissed by the state trial court. Martinez, later represented by a third new attorney, filed a second notice seeking post-conviction relief in state court, claiming for the first time ineffective assistance of trial counsel. The Arizona courts rejected Martinez's claim as procedurally defaulted for not having been raised earlier. The federal district court denied habeas relief on the ground that the Arizona preclusion rule was an adequate and independent state-law ground barring federal review. The district court reasoned that an attorney's errors in post-conviction proceedings do not qualify as cause to excuse procedural default under Coleman v. Thompson, 501 U.S. 722 (1991).  The Ninth Circuit affirmed.

The Supreme Court reversed and remanded. Noting that the right to effective assistance of trial counsel is a "bedrock principle" of the justice system, the Court held that an initial-review collateral proceeding that presents the first opportunity to raise a claim for ineffective assistance of trial counsel is "in many ways the equivalent of a prisoner's direct appeal as to the ineffective-assistance claim." For equitable reasons, therefore, when state law requires that a claim of ineffective trial counsel be raised for the first time in post-conviction proceedings, a prisoner can establish cause for default of the claim in two circumstances: first, if the state court did not appoint counsel in the initial review collateral proceeding; and second, if appointed counsel in the initial-review collateral proceeding was ineffective under Strickland v. Washington, 466 U.S. 668 (1984). The prisoner must also show that the underlying ineffective-assistance-of-trial-counsel claim has some merit. 

Justice Kennedy delivered the opinion of the Court in which Chief Justice Roberts and Justices Ginsburg, Breyer, Alito, Sotomayor, and Kagan joined.  Justice Scalia filed a dissenting opinion, in which Justice Thomas joined.

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