Anthony Juniper v. Keith Davis
737 F.3d 288
4th Cir.2013Background
- Juniper convicted in Virginia circuit court of four counts of capital murder and related felonies; sentenced to death on each capital murder conviction.
- Virginia Supreme Court affirmed citations and U.S. Supreme Court denied certiorari; federal habeas petition later filed in E.D. Va.
- District court denied petition but granted COA on two issues: Brady materiality and Martinez appointment for new counsel.
- Fourth Circuit considered Gray v. Pearson reasoning; vacate in part and remand for independent counsel to pursue Martinez claims when counsel overlapped state and federal habeas cases.
- Martinez v. Ryan held that where state postconviction counsel was ineffective or absent, a federal court may hear substantial ineffective-assistance claims despite procedural defaults.
- Juniper's case is procedurally on all fours with Gray; independent, qualified counsel is ethically required to investigate Martinez claims; district court ordered to appoint such counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| entitlement to independent counsel under Martinez | Juniper | Warden/State | Yes; independent counsel required |
| scope of appointment without substantial Martinez claim | Juniper | State | District court must appoint independent counsel regardless of substantial Martinez claim |
Key Cases Cited
- Martinez v. Ryan, 132 S. Ct. 1309 (2012) (federal habeas can reach defaulted claims if state counsel was ineffective in initial-review collateral proceedings)
- Martel v. Clair, 132 S. Ct. 1276 (2012) (independent counsel required in capital habeas when appointed)