Quintin Jones v. Lorie Davis, Director, 673 F. App'x 369

Quintin Jones beat his 83‑year‑old great aunt to death; arrested the next day on unrelated traffic/drug matters and later interrogated about the murder. He later confessed to two other murders.
Jones was tried, convicted of capital murder in Texas, and sentenced to death; Texas courts affirmed and the U.S. Supreme Court denied certiorari.
Jones filed state and then federal habeas petitions; after multiple procedural developments (including equitable‑tolling litigation), the district court granted leave to file an amended petition and denied relief on six claims.
Jones seeks a certificate of appealability (COA) as to two claims: claim 1a (ineffective assistance for failing to object to denial of counsel at critical stages) and claim 5 (admission at punishment of a Miranda‑violative confession).
The Fifth Circuit reviews whether reasonable jurists could debate the district court’s rulings and whether the underlying claims are substantial or procedurally barred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1a: IAC for failing to object to lack of counsel at interrogations	Jones: trial counsel ineffective for not objecting; Martinez/Trevino excuse procedural default	State: claim procedurally defaulted and not "substantial" under Martinez because counsel’s omission lacked merit	COA denied — claim not substantial; Martinez/Trevino exception not available
Whether Sixth Amendment right to counsel had attached at the interrogations	Jones: arraignment on unrelated drug charge was a pretext and triggered right to counsel extending to subsequent interrogations	State: right is offense‑specific and attaches only after proceedings begin for that offense; interrogations concerned uncharged offenses	Held the right had not attached for those offenses; counsel not ineffective for failing to raise novel extension
Claim 5: Admission at punishment of a Miranda‑violative confession — harmless error	Jones: state court unreasonably applied Chapman; admission was prejudicial even at punishment phase	State: Texas Court of Criminal Appeals found the error harmless beyond a reasonable doubt	COA granted — reasonable jurists could debate whether the harmless‑error application was reasonable
AEDPA statute‑of‑limitations defense to claim 5	State: claim is time‑barred under AEDPA	Jones: procedural record may defeat the defense	Fifth Circuit: noted respondent may have waived the defense in district court; did not foreclose the issue on appeal

Martinez v. Ryan, 566 U.S. 1 (2012) (creates exception to procedural default for substantial IAC claims not raised in initial‑review collateral proceedings when that proceeding lacked counsel)
Trevino v. Thaler, 569 U.S. 413 (2013) (applies Martinez to Texas procedural framework)
Holland v. Florida, 560 U.S. 631 (2010) (equitable tolling principles)
Kirby v. Illinois, 406 U.S. 682 (1972) (Sixth Amendment right to counsel attaches when adversary judicial proceedings begin)
McNeil v. Wisconsin, 501 U.S. 171 (1991) (right to counsel is offense‑specific)
Maine v. Moulton, 474 U.S. 159 (1985) (violation when the State circumvents an attached right to counsel by eliciting statements through subterfuge)
Montejo v. Louisiana, 556 U.S. 778 (2009) (interrogations are critical stages for Sixth Amendment analysis)
Chapman v. California, 386 U.S. 18 (1967) (federal harmless‑beyond‑a‑reasonable‑doubt standard for constitutional error)
Miranda v. Arizona, 384 U.S. 436 (1966) (requirement to advise suspects of rights before custodial interrogation)
United States v. Wade, 388 U.S. 218 (1967) (taking of blood sample not a Sixth Amendment critical stage)