Martinez v. Ryan
132 S. Ct. 1309
| SCOTUS | 2012Background
- Martinez was convicted of two counts of sexual conduct with a minor and sentenced to two life terms without parole after a jury trial with DNA and videotaped interview evidence presented by the prosecution.
- Arizona law bars direct-appeal claims of trial-counsel ineffective assistance and requires such claims to be raised in postconviction collateral proceedings.
- Martinez’s first postconviction counsel filed a Notice of Post-Conviction Relief but did not raise ineffective-assistance claims and later asserted no colorable claims existed.
- The state trial court dismissed the first collateral proceeding for failure to file a pro se petition, and Martinez’s direct appeal proceeded in the meantime.
- A second, later collateral proceeding raised ineffective-assistance claims, but the Arizona Court of Appeals denied relief based on Rule 32.2(a)(3) as having been or could have been raised earlier, and the federal habeas petition followed.
- The question presented concerned whether inadequate assistance of initial-review collateral counsel may excuse a procedural default for an ineffective-assistance-of-trial-counsel claim in federal habeas proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether initial-review collateral counsel's inadequate assistance can excuse default | Martinez: counsel's failure to raise claims provides cause | Arizona/State: Coleman governs; no cause from counsel error | Yes, but only to the limited extent of initial-review collateral proceedings for ineffective-trial-counsel claims. |
| Whether there is a constitutional right to counsel in initial-review collateral proceedings | Martinez asserts right to counsel in initial-review collateral review | State: no constitutional right to counsel in collateral review | No broad constitutional right; only an equitable exception to Coleman for this limited context. |
| AEDPA and 'cause' in procedural-default analysis | §2254(i) bars use of counsel-ineffectiveness as a ground for relief but not as cause | AEDPA does not override cause analysis; default can be excused by ineffective initial counsel | AEDPA does not bar using ineffective-counsel in collateral review to establish cause. |
Key Cases Cited
- Coleman v. Thompson, 501 U.S. 722 (1991) (attorney errors in collateral proceedings generally do not constitute cause; narrow exception for initial-review collateral proceedings)
- Murray v. Carrier, 477 U.S. 478 (1986) (external factors required to excuse procedural default)
- Maples v. Thomas, 565 U.S. 266 (2012) (negligence of postconviction counsel generally not cause; agency principle)
- Halbert v. Michigan, 545 U.S. 605 (2005) (court-appointed counsel in initial-review collateral proceeding can affect merits consideration)
- Edwards v. Carpenter, 529 U.S. 446 (2000) (ineffective assistance matters have implications in federal habeas)
- Pennsylvania v. Finley, 481 U.S. 551 (1987) (no constitutional right to counsel in collateral attacks)
- Gideon v. Wainwright, 372 U.S. 335 (1963) (right to counsel as a foundational principle)