Martinez v. Ryan
566 U. S. ____ (2012) (2012)
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Rule of Law:
Ineffective assistance of counsel in an initial-review state collateral proceeding may establish cause to excuse the procedural default of a claim of ineffective assistance of trial counsel. This creates a narrow, equitable exception to the rule in Coleman v. Thompson for cases where state law requires such claims to be raised for the first time in a collateral proceeding.
Facts:
- Luis Mariano Martinez was convicted of sexual conduct with his 11-year-old stepdaughter.
- The prosecution's evidence included a videotaped interview with the victim and Martinez's DNA found on her nightgown.
- As part of his defense, Martinez introduced evidence that the victim later recanted her accusations, including testimony from her mother and grandmother.
- The victim herself testified at trial and denied that any abuse had occurred.
- To explain the inconsistencies, a prosecution expert testified that it is common for child abuse victims to recant their accusations.
Procedural Posture:
- A jury in an Arizona state trial court convicted Luis Mariano Martinez on two counts of sexual conduct with a minor.
- On direct appeal, Martinez's new counsel could not raise a claim of ineffective assistance of trial counsel because Arizona law requires such claims to be brought in a separate, collateral proceeding.
- While the direct appeal was pending, counsel initiated a state collateral proceeding but then filed a statement declaring she could find no meritorious claims.
- The state trial court dismissed the collateral proceeding.
- Martinez, with new counsel, later filed a second collateral proceeding, this time raising the ineffective assistance of trial counsel claim.
- The state courts dismissed the second proceeding, ruling the claim was procedurally defaulted because it should have been raised in the first collateral proceeding.
- Martinez filed a petition for a writ of habeas corpus in the U.S. District Court for the District of Arizona.
- The District Court denied the petition, holding that under Coleman v. Thompson, errors by post-conviction counsel cannot be 'cause' to excuse a procedural default.
- The U.S. Court of Appeals for the Ninth Circuit affirmed the District Court's decision.
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Issue:
Does ineffective assistance of counsel during an initial-review state collateral proceeding establish cause to excuse the procedural default of a Sixth Amendment ineffective-assistance-of-trial-counsel claim?
Opinions:
Majority - Justice Kennedy
Yes. Inadequate assistance of counsel at initial-review collateral proceedings may establish cause for a prisoner’s procedural default of a claim of ineffective assistance at trial. Where a state deliberately channels claims of ineffective assistance of trial counsel into a collateral proceeding as the first opportunity for review, that proceeding is the functional equivalent of a direct appeal for that specific claim. Denying federal review because of counsel's errors in that critical first proceeding would deny the prisoner any forum to vindicate a potentially meritorious Sixth Amendment claim. This holding is not a new constitutional rule but rather a narrow equitable judgment, modifying the unqualified statement in Coleman v. Thompson that attorney error in postconviction proceedings can never be cause.
Dissenting - Justice Scalia
No. The Court's equitable ruling is functionally identical to, and just as radical as, creating a new constitutional right to counsel in collateral proceedings, a step it pretends to avoid. Established precedent holds that attorney error can only be 'cause' if it is an external factor, which occurs only when the state violates a constitutional duty to provide effective counsel. Since there is no constitutional right to counsel in collateral proceedings, attorney error there is not an external factor and cannot excuse a procedural default. This decision repudiates the core principle of Coleman v. Thompson, undermines the finality of state court judgments, and will force states to litigate the effectiveness of collateral-review counsel in federal court, effectively eliminating procedural default for these claims.
Analysis:
This decision significantly modifies the doctrine of procedural default established in Coleman v. Thompson. It creates a critical exception that allows federal courts to hear ineffective-assistance-of-trial-counsel claims that would otherwise be barred due to the errors of post-conviction counsel. The ruling addresses a structural problem in states like Arizona where such claims cannot be raised on direct appeal, making the first collateral proceeding the only realistic chance for a defendant to raise them. The dissent warns this 'equitable' distinction is meaningless and will practically force states to provide effective counsel in all initial collateral reviews to avoid federal habeas litigation, thereby undermining state court finality.
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