Martel v. Clair, 132 S. Ct. 1276

Clair was charged with capital murder in California and sentenced to death, with key evidence from a secretly recorded conversation by his former girlfriend.
Clair commenced federal habeas proceedings in 1994; the district court appointed counsel under 18 U.S.C. §3599 and later substituted the Federal Public Defender (FPD) as counsel of record.
In 2005 Clair moved to substitute counsel, alleging breakdown with the FPD and new failing to test undisclosed physical evidence; the district court denied the motion and Clair’s habeas petition.
Ninth Circuit vacated, holding substitution should be governed by the non-capital ‘interests of justice’ standard from §3006A; remanded for appropriate remedy given Clair had new counsel on appeal.
The Supreme Court granted certiorari and held that the §3599 substitution standard is the same ‘interests of justice’ standard as §3006A, and that the district court did not abuse its discretion in denying the second substitution request.
The Court emphasized that §3599’s reforms aim to ensure higher quality representation in capital cases, and that substitution decisions remain highly fact-specific and reviewable for abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What standard governs §3599 substitution motions in capital cases?	Clair urged the ‘interests of justice’ standard from §3006A.	State urged a stricter, 'no substitution absent denial' standard as proposed by its construction.	Courts should use the 'interests of justice' standard from §3006A.
Did the district court abuse its discretion denying Clair's second substitution request?	Clair contends new evidence and breakdown warranted new counsel.	The court correctly declined to change counsel given timing and lack of impact on claims.	No abuse of discretion; denial was permissible under the circumstances.

McFarland v. Scott, 512 U.S. 849 (1994) (capital representation quality matters for fairness)
Harbison v. Bell, 556 U.S. 180 (2009) (Sixth Amendment and counsel standards in capital/post-conviction contexts)
Murray v. Giarratano, 492 U.S. 1 (1989) (no Sixth Amendment right to counsel in habeas proceedings)
Coleman v. Thompson, 501 U.S. 722 (1991) (counsel and equitable tolling considerations in habeas)
Mayle v. Felix, 545 U.S. 644 (2005) (timeliness and exhaustion in post-conviction relief)
Hunter v. Delo, 62 F.3d 271 (1995) (timeliness and substitution of counsel in capital/habeas contexts)
United States v. Prime, 431 F.3d 1147 (2005) (interests-of-justice considerations in substitution of counsel)
United States v. Doe, 272 F.3d 116 (2001) (on-record inquiry into defendant’s complaints for counsel substitution)
United States v. Taylor, 487 U.S. 326 (1988) (necessity of reasoned questioning when denying substitution of counsel)