US SUPREME COURT DECISIONS
Martinez v. Ryan
Opinion Summary:
Arizona prisoners could raise claims of ineffective assistance of trial counsel only in state collateral proceedings, not on direct review. In petitioner's first state collateral proceeding, his counsel did not raise such a claim. On federal habeas review with new counsel, petitioner argued that he received ineffective assistance both at trial and in his first state collateral proceeding. He also claimed that he had a constitutional right to an effective attorney in the collateral proceeding because it was the first place to raise his claim of ineffective assistance at trial. The Court held that where, under state law, ineffective-assistance-of-trial-counsel claims must be raised in an initial-review collateral proceeding, a procedural default would not bar a federal habeas court from hearing those clams if, in the initial-review collateral proceeding, there was no counsel or counsel in the proceeding was ineffective. Therefore, the Court reversed the judgment of the Ninth Circuit.NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321 .
SUPREME COURT OF THE UNITED STATES
Syllabus
MARTINEZ v. RYAN, DIRECTOR, ARIZONA DEPARTMENT OF CORRECTIONS
certiorari to the united states court of appeals for the ninth circuit
No. 10–1001. Argued October 4, 2011—Decided March 20, 2012
Arizona prisoners may raise claims of ineffective assistance of trial counsel only in state collateral proceedings, not on direct review. In petitioner Martinez’s first state collateral proceeding, his counsel did not raise such a claim. On federal habeas review with new counsel, Martinez argued that he received ineffective assistance both at trial and in his first state collateral proceeding. He also claimed that he had a constitutional right to an effective attorney in the collateral proceeding because it was the first place to raise his claim of ineffective assistance at trial. The District Court denied the petition, finding that Arizona’s preclusion rule was an adequate and independent state-law ground barring federal review, and that under Coleman v. Thompson, 501 U. S. 722 , the attorney’s errors in the postconviction proceeding did not qualify as cause to excuse the procedural default. The Court of Appeals for the Ninth Circuit affirmed:chanrobles.com-red
Held:clubjurisvirtuallawlibrary
1. Where, under state law, ineffective-assistance-of-trial-counsel claims must be raised in an initial-review collateral proceeding, a procedural default will not bar a federal habeas court from hearing those claims if, in the initial-review collateral proceeding, there was no counsel or counsel in that proceeding was ineffective. Pp. 5–14:chanrobles.com-red
(a) Given that the precise question here is whether ineffective assistance in an initial-review collateral proceeding on an ineffective-assistance-at-trial claim may provide cause for a procedural default in a federal habeas proceeding, this is not the case to resolve the question left open in Coleman: whether a prisoner has a constitutional right to effective counsel in initial-review collateral proceedings. However, to protect prisoners with potentially legitimate ineffective-assistance claims, it is necessary to recognize a narrow exception to Coleman’s unqualified statement that an attorney’s ignorance or inadvertence in a postconviction proceeding does not qualify as cause to excuse a procedural default, namely, that inadequate assistance of counsel at initial-review collateral proceedings may establish cause. Pp. 5–6:chanrobles.com-red
(b) A federal court can hear Martinez’s ineffective-assistance claim only if he can establish cause to excuse the procedural default and prejudice from a violation of federal law. Coleman held that a postconviction attorney’s negligence “does not qualify as ‘cause,’ ” because “the attorney is the prisoner’s agent,” and “the principal bears the risk of” his agent’s negligent conduct, Maples v. Thomas, ante, at 12. However, in Coleman, counsel’s alleged error was on appeal from an initial-review collateral proceeding. Thus, his claims had been addressed by the state habeas trial court. This marks a key difference between initial-review collateral proceedings and other collateral proceedings. Here, where the initial-review collateral proceeding is the first designated proceeding for a prisoner to raise the ineffective-assistance claim, the collateral proceeding is the equivalent of a prisoner’s direct appeal as to that claim because the state habeas court decides the claim’s merits, no other court has addressed the claim, and defendants “are generally ill equipped to represent themselves” where they have no brief from counsel and no court opinion addressing their claim. Halbert v. Michigan, 545 U. S. 605 . An attorney’s errors during an appeal on direct review may provide cause to excuse a procedural default; for if the attorney appointed by the State is ineffective, the prisoner has been denied fair process and the opportunity to comply with the State’s procedures and obtain an adjudication on the merits of his claim. Without adequate representation in an initial-review collateral proceeding, a prisoner will have similar difficulties vindicating a substantial ineffective-assistance-at-trial claim. The same would be true if the State did not appoint an attorney for the initial-review collateral proceeding. A prisoner’s inability to present an ineffective-assistance claim is of particular concern because the right to effective trial counsel is a bedrock principle in this Nation’s justice system:chanrobles.com-red
Allowing a federal habeas court to hear a claim of ineffective assistance at trial when an attorney’s errors (or an attorney’s absence) caused a procedural default in an initial-review collateral proceeding acknowledges, as an equitable matter, that a collateral proceeding, if undertaken with no counsel or ineffective counsel, may not have been sufficient to ensure that proper consideration was given to a substantial claim. It thus follows that, when a State requires a prisoner to raise a i claim of ineffective assistance at trial in a collateral proceeding, a prisoner may establish cause for a procedural default of such claim in two circumstances: where the state courts did not appoint counsel in the initial-review collateral proceeding for an ineffective-assistance-at-trial claim; and where appointed counsel in the initial-review collateral proceeding, where that claim should have been raised, was ineffective under Strickland v. Washington, 466 U. S. 668 . To overcome the default, a prisoner must also demonstrate that the underlying ineffective-assistance-at-trial claim is substantial. Most jurisdictions have procedures to ensure counsel is appointed for substantial ineffective-assistance claims. It is likely that such attorneys are qualified to perform, and do perform, according to prevailing professional norms. And where that is so, States may enforce a procedural default in federal habeas proceedings. Pp. 6–12:chanrobles.com-red
(c) This limited qualification to Coleman does not implicate stare decisis concerns. Coleman’s holding remains true except as to initial-review collateral proceedings for claims of ineffective assistance at trial. The holding in this case should not put a significant strain on state resources. A State facing the question of cause for an apparent default may answer that the ineffective-assistance-of-trial-counsel claim is insubstantial. The limited circumstances recognized here also reflect the importance of the right to effective assistance at trial. Other claims may not implicate the same fundamentals of the adversary system. The Antiterrorism and Effective Death Penalty Act of 1996 does not speak to the question presented here, and thus does not bar Martinez from asserting attorney error as cause for a procedural default. Pp. 12–14:chanrobles.com-red
2. Whether Martinez’s attorney in his first collateral proceeding was ineffective and whether his ineffective-assistance-at-trial claim is substantial, as well as the question of prejudice, are questions that remain open for a decision on remand. P. 15:chanrobles.com-red
623 F. 3d 731, reversed and remanded:chanrobles.com-red
Kennedy, J., delivered the opinion of the Court, in which Roberts, C.J., and Ginsburg, Breyer, Alito, Sotomayor, and Kagan, JJ., joined. Scalia, J., filed a dissenting opinion, in which Thomas, J., joined.
