Anthony Haynes v. Rick Thaler, Director
489 F. App'x 770
5th Cir.2012Background
- Haynes was convicted of shooting and killing an off-duty police officer and sentenced to death.
- He sought state and federal habeas review, raising ineffective assistance of trial counsel during mitigation.
- The district court denied relief for failure to exhaust; most claims, including Strickland, were unexhausted here.
- Martinez v. Ryan recognized a limited equitable exception allowing review if state habeas counsel was ineffective, but Ibarra held Martinez does not apply to Texas capital petitions.
- The district court denied Haynes’s Rule 60(b)(6) motion; the court found Martinez did not warrant relief, and Ibarra foreclosed relief.
- The majority denied a COA and stayed relief; the dissent would grant COA and a stay pending appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Martinez's equitable exception applies to Texas capital petitions | Haynes argues Martinez excuses default due to ineffective state habeas counsel. | The majority adheres to Ibarra, limiting Martinez's exception in Texas capital cases. | Martinez exception does not apply to Texas capital petitions per Ibarra. |
| Whether Rule 60(b)(6) relief is available to Haynes | Martinez creates extraordinary circumstances justifying relief from judgment. | Adams and Gonzalez bar Rule 60(b)(6) relief absent extraordinary circumstances; Martinez is inapplicable here. | Relief denied; Martinez does not warrant Rule 60(b)(6) relief under current posture. |
| Whether Haynes should receive a COA to appeal | Haynes's underlying Strickland claim has merit and warrants further review. | The district court properly denied; no substantial issue shown for COA. | COA denied in the majority view. |
| Whether Ibarra should foreclose relief despite Martinez | Ibarra should be distinguishable; Martinez should be extended to Texas collateral context. | Ibarra controls and Martinez does not create relief for Texas petitioners. | Ibarra forecloses relief; Martinez not extended here. |
Key Cases Cited
- Martinez v. Ryan, 132 S. Ct. 1309 (2012) (equitable exception to procedural default for ineffective-assistance claims when state postconviction counsel is deficient)
- Coleman v. Thompson, 501 U.S. 722 (1991) (procedural default principles and absence of right to counsel in collateral review)
- Ibarra v. Thaler, 687 F.3d 222 (5th Cir. 2012) ( Martinez does not create equitable relief for Texas capital petitions)
- Adams v. Thaler, 679 F.3d 312 (5th Cir. 2012) (distinguishes when 60(b)(6) relief is available post-Martinez)
- Gonzalez v. Crosby, 545 U.S. 524 (2005) (Rule 60(b)(6) extraordinary-circumstances standard)
- Mata v. State, 226 S.W.3d 425 (Tex. Crim. App. 2007) (Texas postconviction procedure and when to raise ineffective-assistance claims)