Jamaar Williams v. Jackie Crawford
669 F. App'x 846
| 9th Cir. | 2016Background
- Williams, a Nevada inmate, filed a second amended federal habeas petition asserting ineffective assistance of trial and appellate counsel.
- The district court dismissed Grounds Two and Three(a)-(c) as procedurally defaulted.
- The district court did not apply Martinez v. Ryan to excuse the defaults.
- Martinez requires four conditions to excuse procedural default; three of these are satisfied here (Williams was unrepresented in initial state habeas, and state habeas proceedings are the initial review proceeding, with claims properly raised there).
- The court remanded to allow further factual development and to assess whether the claims are substantial under Martinez, citing Woods and related authority.
- This opinion vacates the district court’s dismissal and remands for further proceedings consistent with Martinez and subsequent Ninth Circuit guidance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Martinez applies to excuse Williams’s procedural default. | Williams’s default should be excused under Martinez. | District court correctly determined procedural default; Martinez not triggered. | Remand to determine substantiality under Martinez. |
| Whether Williams was entitled to an evidentiary hearing to develop the record on substantiality. | Record development is needed to show the claims are substantial. | No evidentiary hearing was held; proper standard not applied. | Remand to determine if an evidentiary hearing is warranted. |
| Whether the district court erred by dismissing Grounds Two and Three without applying Martinez. | Martinez dictates evaluation of default and potential relief. | Dismissal was proper under the state of record. | Vacate and remand for Martinez-based evaluation. |
Key Cases Cited
- Martinez v. Ryan, 132 S. Ct. 1309 (2012) (excuses procedural default under four-part test)
- Dickens v. Ryan, 740 F.3d 1302 (9th Cir. 2014) (en banc; clarifies substantiality and evidentiary hearing scope)
- Trevino v. Thaler, 133 S. Ct. 1911 (2013) (extends Martinez on the scope of initial-review proceedings)
- Nguyen v. Curry, 736 F.3d 1287 (9th Cir. 2013) (extends Martinez to appellate-counsel issues)
- Rippo v. State, 122 Nev. 1086 (2006) (state post-conviction review as initial review for certain claims)
- Pellegrini v. State, 117 Nev. 860 (2001) (claims properly raised in initial post-conviction petition)
- Woods v. Sinclair, 764 F.3d 1109 (9th Cir. 2014) (recognizes need for factual development in Martinez analysis)
- Holbrook v. Woods, 135 S. Ct. 2311 (2015) (Supreme Court recognition related to Martinez scope)