Jermont Cox v. Martin Horn
757 F.3d 113
| 3rd Cir. | 2014Background
- Jermont Cox was convicted of first-degree murder and related offenses in Philadelphia in 1993 and sentenced to life imprisonment.
- Cox filed a federal habeas petition in 2000; the district court dismissed in 2004 for procedural default on most claims.
- This Court affirmed the dismissal in 2006; Martinez v. Ryan later created a potential cause-exception for defaulted claims related to ineffective assistance.
- Cox filed a Rule 60(b)(6) motion in 2012 seeking relief based on Martinez's change in law; the district court denied it.
- The Third Circuit vacated and remanded to allow a full 60(b)(6) analysis with Martinez guidance and potential extra briefing.
- The court emphasizes the 60(b)(6) standard requires extraordinary circumstances and case-specific evaluation, not a blanket rule.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Martinez as an extraordinary circumstance | Martinez provides cause to excuse default and reopen review. | Martinez alone is insufficient for 60(b)(6) relief; requires additional factors. | Martinez alone not enough; remand for case-specific 60(b)(6) equitable analysis. |
| Adams v. Thaler and per se rule | Adams should not control; Martinez and factors should be weighed. | Adams supports treating Martinez as insufficient by itself. | Court rejects per se rule; adopts case-by-case equitable approach consistent with Martinez. |
Key Cases Cited
- Martinez v. Ryan, 132 S. Ct. 1309 (2012) (establishes limited Martinez exception for post-conviction counsel ineffectiveness)
- Trevino v. Thaler, 133 S. Ct. 1911 (2013) (extends Martinez to states where meaningful ineffective-assistance review is impractical)
- Gonzalez v. Crosby, 545 U.S. 524 (2005) (change in law not per se extraordinary for 60(b)(6))
- Adams v. Thaler, 679 F.3d 312 (2012) (per se rule rejecting Martinez relief; need case-specific factors)
- Coltec Indus., Inc. v. Hobgood, 280 F.3d 262 (2002) (explicitly allows considering equitable factors in 60(b)(6) analysis)
- Morris v. Horn, 187 F.3d 333 (1999) (60(b)(6) requires extraordinary circumstances)