Thursday, January 31, 2013

Maples v. Thomas case brief

Maples v. Thomas case summary
132 S. Ct. 912

PROCEDURAL HISTORY: Petitioner state prisoner filed a petition for a writ of habeas corpus, challenging his murder conviction and death sentence. The district court denied the petition and the United States Court of Appeals for the Eleventh Circuit affirmed, finding a procedural default in state court based on the prisoner's failure timely to appeal the Alabama trial court's order denying him postconviction relief. Certiorari was granted.

OVERVIEW: The prisoner's postconviction petition, which sought relief in state court based on ineffective assistance of counsel, was written by two New York attorneys associated with a New York-based law firm. While the postconviction petition remained pending, his New York attorneys left the firm. When his petition was denied, notices were sent to the attorneys at the firm's address, but they were returned, unopened, to the trial court clerk, who attempted no further mailing. The prisoner's time to appeal ran out. The federal courts found procedural default. The Supreme Court determined that there was "cause" to excuse the missed notice of appeal deadline because (1) the prisoner showed that his attorneys of record abandoned him because the New York attorneys' departure from the law firm and their commencement of employment that prevented them from representing him ended their agency relationship with him, other attorneys at the firm had no authority to act for him, and local Alabama counsel did not serve as his agent in any meaningful sense of that word, and (2) he had no reason to suspect that he lacked counsel able and willing to represent him during the time permitted for an appeal.

CONCLUSION: The Court reversed the federal appellate court's judgment and remanded the case for further proceedings. 7-2 Decision; 1 Concurrence; 1 Dissent.

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