Maples v. Thomas, 132 S. Ct. 912

Maples, Alabama death-row inmate, sought state postconviction relief in 2001; his counsel were two New York-based associates who appeared pro hac vice with local counsel Butler.
In 2002, the New York attorneys left Sullivan & Cromwell for new positions but did not inform Maples or seek withdrawal/con substitution; Butler stated he would only facilitate pro hac vice appearance and would not handle substantive issues.
In 2003, the Alabama trial court denied Maples’ Rule 32 petition; notices were sent to the New York firm but unopened and returned; no attorney of record appeared to act, so no appeal was filed within 42 days.
Maples then pursued federal habeas; lower courts held his claims defaulted due to failure to appeal timely and rejected “cause” to excuse the default, noting Coleman’s rule that postconviction counsel’s ineffectiveness cannot be ‘cause’.
The Supreme Court reversed, holding that Maples showed ‘cause’ to excuse the default because he was abandoned by counsel, who ceased acting as his agents without notifying him or seeking withdrawal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether abandonment by counsel constitutes cause to excuse default	Maples argues abandonment by his counsel supplied extraordinary circumstances.	State contends Coleman prevents attorney missteps from excusing default; does not recognize abandonment.	Yes; abandonment qualifies as cause to excuse the default.
Was Maples effectively unrepresented during the critical 42-day appeal window	He had no functioning attorneys of record; counsel ceased representation without notice.	Some Sullivan & Cromwell attorneys remained associated with the case; Butler may have represented.	Maples was effectively unrepresented; abandonment occurred.
Did local counsel Butler act as Maples' agent during the relevant period	Butler had a limited role but was listed as local counsel; other firm attorneys worked on the case.	Butler did not actively represent or notify; he did not withdraw or file notices.	Butler did not meaningfully represent Maples; abandonment by others still occurred.

Coleman v. Thompson, 501 U.S. 722 (1991) (attorney error generally not cause unless defendant lacks counsel in postconviction)
Holland v. Florida, 560 U.S. 631 (2010) (attorney neglect may constitute extraordinary circumstance for tolling)
Jones v. Flowers, 547 U.S. 220 (2006) (due process notice duties when notices are returned)
Murray v. Carrier, 477 U.S. 478 (1986) (cause and prejudice framework for federal review of state defaults)
Irwin v. Department of Veterans Affairs, 498 U.S. 89 (1990) (agency law: clients bound by actions of their attorney-agent)
Link v. Wabash R. Co., 370 U.S. 626 (1962) (principles of agency when attributing attorney conduct)