Thursday, January 31, 2013

Martinez v. Ryan case brief

Martinez v. Ryan case summary
132 S. Ct. 1309

PROCEDURAL POSTURE: A district court denied petitioner inmate's habeas claim of ineffective assistance of trial counsel, ruling that Ariz. Rule Crim. P. 32.2(a)(3) was an adequate and independent state-law ground to bar federal review and no case was shown to excuse the procedural default since postconviction counsel's errors did not qualify as cause for a default. The U.S. Court of Appeals for the Ninth Circuit affirmed. Certiorari was granted.

OVERVIEW: Where, under state law, claims of ineffective assistance (IA) of trial counsel had to be raised in an initial-review collateral proceeding (IRCP), a procedural default would not bar a federal habeas court from hearing a substantial claim of IA at trial if, in the IRCP, there was no counsel or counsel in that proceeding was ineffective. The inmate's attorney in the IRCP filed a notice akin to an Anders brief, in effect conceding a lack of any meritorious claim, including a claim of IA at trial, which the inmate argued was IA. The Ninth Circuit did not decide if it was. Rather, it held that because he did not have a right to an attorney in the IRCP, the attorney's errors in the IRCP could not establish cause for the failure to comply with the State's rules. Thus, the Ninth Circuit did not determine if the attorney in the IRCP was ineffective or whether the claim of IA of trial counsel was substantial. Nor was prejudice addressed. Those issues remained open for a decision on remand. While 28 U.S.C.S. § 2254(i) precluded relying on IA of a postconviction attorney as a "ground for relief," it did not stop its use to establish "cause" to excuse procedural default.

OUTCOME: The judgment upholding the denial of habeas relief was reversed, and the case was remanded for further proceedings. 7-2 decision; 1 opinion, 1 dissent.

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