Roberto Mata v. Tyrone Baker, 74 F.4th 480

Background

In March 2002 Mata shot three men, killing two; he was arrested and gave a 22‑minute videotaped statement in which he acknowledged Miranda warnings and said the statement was voluntary.
Defense filed a pretrial motion to suppress oral, written, and videotaped statements alleging coercion and abuse, but the trial court only conducted a hearing on evidence seized from Mata’s home and suppressed that evidence; the suppression hearing on the statements was never held before trial.
The State played Mata’s videotaped confession at trial; Mata also testified and offered a self‑defense/defense‑of-another theory; the jury convicted him of two counts of first‑degree murder and one count of aggravated battery with a firearm.
On direct appeal the Illinois Appellate Court rejected an unrelated ineffective‑assistance claim; Mata filed a pro se postconviction petition arguing trial counsel was ineffective for abandoning the suppression motion and appellate counsel was ineffective for not raising that issue on direct appeal; the state courts denied relief, concluding the claim was waived because it could have been raised on direct appeal.
Mata filed a federal habeas petition; the district court denied relief concluding Mata procedurally defaulted his ineffective‑assistance‑of‑trial‑counsel claim and that his appellate‑ineffectiveness claim did not excuse the default; the Seventh Circuit granted COA only on the procedural‑default issue.
The Seventh Circuit affirmed, holding the Illinois waiver rule was an adequate and independent state ground barring federal review, and Mata failed to show cause to excuse the default because his appellate‑ineffectiveness claim itself was unexhausted.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mata’s claim that trial counsel was ineffective for failing to pursue a suppression hearing is procedurally defaulted	Mata: claim merits review because counsel ‘‘ought to have’’ pursued suppression; factual basis may lie outside the record	State: Illinois courts found waiver because the claim arose from matters in the trial record, so it was forfeited by not raising it on direct appeal	Held: Procedurally defaulted — Illinois waiver is an adequate and independent state ground barring federal habeas review
Whether appellate counsel’s alleged ineffectiveness excuses the procedural default of the trial‑counsel claim (cause and prejudice)	Mata: appellate counsel was ineffective for not raising trial counsel’s failure on direct appeal, which should excuse the default	State: Mata failed to exhaust the ineffective‑assistance‑of‑appellate‑counsel claim in the Illinois Supreme Court, so it is itself defaulted and cannot establish cause	Held: Mata defaulted the appellate‑ineffectiveness claim (did not raise it in petition for leave to appeal), so it cannot excuse the procedural default

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)
Coleman v. Thompson, 501 U.S. 722 (1991) (procedural default doctrine; cause and prejudice framework)
Davila v. Davis, 137 S. Ct. 2058 (2017) (federal courts barred from reviewing claims defaulted in state court on adequate and independent state grounds)
Wilson v. Cromwell, 69 F.4th 410 (7th Cir. 2023) (de novo review of procedural‑default determinations)
Sturgeon v. Chandler, 552 F.3d 604 (7th Cir. 2009) (Illinois waiver rule is an adequate and independent state ground)
Smith v. Gaetz, 565 F.3d 346 (7th Cir. 2009) (Illinois waiver doctrine bars habeas review of raised‑on‑direct‑appeal issues)
People v. Erickson, 641 N.E.2d 455 (Ill. 1994) (Illinois rule: claims that depend on facts outside the trial record may avoid waiver)
People v. Harris, 862 N.E.2d 960 (Ill. 2007) (application of waiver to matters appearing in the trial record)
Edwards v. Carpenter, 529 U.S. 446 (2000) (ineffective‑assistance claim asserted as cause must itself be exhausted or not defaulted)
Wilson v. Sellers, 138 S. Ct. 1188 (2018) (federal habeas review looks to the last state‑court decision that provided a relevant rationale)