Shinn v. Martinez Ramirez, 596 U.S. 366

Background

David Ramirez and Barry Lee Jones were convicted of capital crimes in Arizona and sentenced to death; both later sought federal habeas relief under 28 U.S.C. §2254 claiming trial counsel was ineffective for inadequate investigation.
Each failed to present the specific ineffective-assistance-of-trial-counsel claim in state court in the manner required by Arizona, producing procedural defaults on federal habeas review.
Both invoked Martinez v. Ryan to argue that ineffective assistance of state postconviction counsel constitutes "cause" to excuse their procedural defaults and sought to develop new evidence in federal court to prove cause, prejudice, and the merits of the underlying claims.
The District Courts (and in Jones a seven-day evidentiary hearing) admitted new evidence; the Ninth Circuit held that Martinez permitted federal evidentiary development and remanded for further factfinding.
The State petitioned, arguing 28 U.S.C. §2254(e)(2) bars federal courts from holding evidentiary hearings or considering new evidence when the state-court record was not developed due to negligent postconviction counsel; the Supreme Court granted certiorari and reversed the Ninth Circuit.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §2254(e)(2) allows federal courts to hold evidentiary hearings or consider new evidence to excuse procedural default when state postconviction counsel was ineffective	Martinez allows equitable excusal of default and requires courts to permit evidentiary development when postconviction counsel was ineffective	AEDPA §2254(e)(2) bars evidentiary hearings or consideration of new evidence unless its narrow statutory exceptions are met; postconviction counsel's failures are attributed to the prisoner	Court held §2254(e)(2) bars federal evidentiary development or consideration of new evidence based on negligent or ineffective state postconviction counsel; petitioner is "at fault" for undeveloped record absent §2254(e)(2) exceptions.
Whether a "Martinez hearing" (to prove cause & prejudice) may admit new evidence that can later be used on the merits even if §2254(e)(2) exceptions are not satisfied	Evidence admitted to prove cause & prejudice may be considered on the merits; otherwise Martinez is hollow	Holland and §2254(e)(2) prevent an end-run: evidence admitted for Martinez cannot be used on the merits unless §2254(e)(2) requirements are met	Court held Holland forecloses using evidence admitted at a Martinez-style hearing to decide the merits unless §2254(e)(2) permits the hearing or admission.
Whether Martinez’s equitable rule can be judicially expanded to override the statutory text of §2254(e)(2)	Martinez should be extended to excuse §2254(e)(2)’s bar where postconviction counsel’s ineffectiveness caused failure to develop the record	Courts cannot rewrite a statute; equitable Martinez exception cannot displace AEDPA’s clear limits	Court held it lacks authority to amend §2254(e)(2); Martinez remains a narrow equitable rule but does not permit bypassing AEDPA’s statutory constraints.

Key Cases Cited

Coleman v. Thompson, 501 U.S. 722 (procedural-default doctrine; attorney error generally attributable to petitioner)
Martinez v. Ryan, 566 U.S. 1 (narrow equitable rule: ineffective postconviction counsel can be "cause" to excuse default of trial-ineffectiveness claims)
Williams v. Taylor, 529 U.S. 420 (interpretation of "failed to develop" in §2254(e)(2); petitioner at fault standard)
Keeney v. Tamayo-Reyes, 504 U.S. 1 (pre-AEDPA rule that negligent failure to develop state record requires cause-and-prejudice showing)
Holland v. Jackson, 542 U.S. 649 (per curiam) (§2254(e)(2) restrictions apply even where no formal evidentiary hearing is held)
Schriro v. Landrigan, 550 U.S. 465 (district court must assess whether evidentiary hearing could produce facts entitling relief)
McQuiggin v. Perkins, 569 U.S. 383 (AEDPA generally bars evidentiary hearings except in extraordinary cases)
Harrington v. Richter, 562 U.S. 86 (habeas is an extraordinary remedy; limits on federal review)
Trevino v. Thaler, 569 U.S. 413 (extends Martinez where States’ procedures effectively foreclose direct review)
Engle v. Isaac, 456 U.S. 107 (federal habeas review intrudes on state sovereignty; costs of federal intervention)
Calderon v. Thompson, 523 U.S. 538 (finality and state interest in punishment and repose)
Wainwright v. Sykes, 433 U.S. 72 (federal intervention undermines finality and state trial system)