Luke Hunton v. Stephen Sinclair, 732 F.3d 1124

Hunton was convicted in Washington of bank robbery and sentenced to life under the state’s three‑strikes law. He raised a Brady due‑process/discovery claim on direct appeal; the Washington Court of Appeals declined to consider it because the factual basis lay outside the appellate record.
Hunton filed a pro se personal restraint petition (state collateral review) but did not raise the Brady claim; Washington provides counsel for PRPs only in limited circumstances that did not apply.
After state courts denied relief, Hunton filed a federal habeas petition under 28 U.S.C. § 2254 asserting the Brady claim; the district court dismissed that claim as procedurally defaulted.
Hunton argued he should be excused from Coleman procedural‑default rules because he lacked counsel (or had ineffective counsel) in the state collateral proceeding and thus should be able to litigate his Brady claim in federal habeas.
The Ninth Circuit majority affirmed, holding Coleman governs and Martinez’s limited exception for ineffective assistance in initial collateral review applies only to trial‑IAC claims as described by the Supreme Court; the dissent would have applied Martinez to Brady claims and remanded for Martinez‑test analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hunton may overcome procedural default of his Brady claim because he was without counsel or had ineffective counsel in state collateral review	Hunton: Martinez exception applies; lack/ineffectiveness of collateral counsel excuses default so federal review of Brady claim is permitted	State/Court: Coleman bars using ineffective assistance of collateral counsel to excuse procedural default except as narrowly defined by Martinez for trial‑IAC claims	Held: Affirmed — Coleman controls; Martinez’s limited exception does not extend to Hunton’s Brady claim under the Court’s characterization
Whether Martinez created a general exception to Coleman for attorney errors in initial collateral proceedings beyond trial‑IAC claims	Hunton: Martinez’s rationale (need for counsel to develop out‑of‑record evidence and vindicate fundamental rights) applies equally to Brady claims	State/Court: Martinez expressly limited its exception to trial‑IAC claims in the specific circumstances described; courts must follow that limit	Held: Martinez is limited; lower courts may not expand it — only the Supreme Court may overrule Coleman’s rule more broadly

Coleman v. Thompson, 501 U.S. 722 (1991) (procedural default rule: no constitutional right to counsel in state collateral proceedings; attorney error there generally not cause to excuse default)
Martinez v. Ryan, 566 U.S. 1 (2012) (limited exception to Coleman: inadequate counsel in initial‑review collateral proceeding may establish cause to excuse default for a trial‑IAC claim)
Trevino v. Thaler, 569 U.S. 413 (2013) (applies/expands Martinez where state procedures make it practically impossible to raise trial‑IAC on direct appeal)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecution’s suppression of exculpatory evidence violates due process)
Amadeo v. Zant, 486 U.S. 214 (1988) (government suppression that prevents counsel from making objections may constitute cause to excuse procedural default)
Strickler v. Greene, 527 U.S. 263 (1999) (Brady framework and extension to inadvertent suppression)
Rodriguez de Quijas v. Shearson/Am. Express, Inc., 490 U.S. 477 (1989) (lower courts must follow controlling Supreme Court precedent until the Supreme Court overrules it)
Agostini v. Felton, 521 U.S. 203 (1997) (principle that lower courts must adhere to Supreme Court precedent)