Martinez v. Ryan

Last updated

Martinez v. Ryan
Seal of the United States Supreme Court.svg
Argued October 4, 2011
Decided March 20, 2012
Full case nameLuis Mariano Martinez v. Charles L. Ryan, Director, Arizona Department of Corrections
Docket no. 10-1001
Citations566 U.S. 1 ( more )
132 S. Ct. 1309; 182 L. Ed. 2d 272
Argument Oral argument
Case history
PriorMartinez v. Schriro, 623 F.3d 731 (9th Cir. 2010)
SubsequentMartinez v. Ryan, 680 F.3d 1160 (9th Cir. 2012)
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia  · Anthony Kennedy
Clarence Thomas  · Ruth Bader Ginsburg
Stephen Breyer  · Samuel Alito
Sonia Sotomayor  · Elena Kagan
Case opinions
MajorityKennedy, joined by Roberts, Ginsburg, Breyer, Alito, Sotomayor, and Kagan
DissentScalia, joined by Thomas

Martinez v. Ryan, 566 U.S. 1 (2012), was a United States Supreme Court case which considered whether criminal defendants ever have a right to the effective assistance of counsel in collateral state post-conviction proceedings. The Court held that a procedural default will not bar a federal habeas court from hearing ineffective-assistance-of-trial-counsel if there was no counsel or ineffective counsel in an initial-review collateral proceeding.

Contents

Background

Luis Mariano Martinez was accused of sexual misconduct with his eleven-year-old stepdaughter, who recanted her accusations. [1] Martinez was convicted on two counts of sexual conduct with someone under the age of fifteen and was sentenced to two consecutive terms of thirty-five years to life. [2] [3] On direct appeal, the Arizona Court of Appeals affirmed the conviction. Martinez's first state-appointed appellate lawyer had filed a notice of post-conviction relief and, without notifying Martinez, had requested forty-five days for Martinez to file a pro se petition. [3] Martinez obtained a second appellate lawyer who filed a new petition for post-conviction relief that alleged ineffective assistance on the part of Martinez's trial lawyer. [3] The court claimed Martinez had defaulted on the claim by not raising it in his first post-conviction motion. [3]

The Arizona Supreme Court denied review. Martinez then petitioned for a writ of habeas corpus, alleging that the right to effective assistance of counsel should extend to all collateral post-conviction relief proceedings in which a defendant has the first opportunity to raise a substantive challenge to his conviction. [4] He argued that his court-appointed appellate attorney had failed to raise a claim in his first post-conviction proceeding that his lawyer at trial provided ineffective assistance. [3] The United States District Court for the District of Arizona denied the petition, concluding that federal review was barred because the Arizona procedural rules were "adequate and independent." [3]

The District Court's decision was unanimously affirmed by the United States Court of Appeals for the Ninth Circuit which held that since there is no constitutional right to appointment of counsel during a defendant's post-conviction relief petition, there is no right to effective assistance of counsel. [3] The court claimed that, although collateral proceedings might provide the first tier of review for a particular claim, Martinez had already benefitted from the assistance of counsel in a direct appeal. [2] [3] Martinez sought certiorari. [3]

Supreme Court decision

On March 20, 2012, the Supreme Court issued a 7-2 decision written by Justice Anthony Kennedy, which created an exception to its 1991 holding in Coleman v. Thompson. [5] [1] Coleman v. Thompson held that attorney errors in post-conviction hearings do not qualify as cause to excuse procedural defaults. [1] In the opinion for Martinez v. Ryan, the Court held that if state law requires ineffective-assistance-of-trial-counsel claims to be raised in an initial-review collateral proceeding, then a procedural default will not bar a federal habeas court from hearing those claims if there was no counsel or there was ineffective counsel in an initial-review collateral proceeding. [6] Justice Kennedy wrote that "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." [7] The judgement of the Court of Appeals was reversed and remanded. [5]

Dissent

Justice Antonin Scalia dissented and was joined by Justice Clarence Thomas. [5] Scalia claimed that the majority opinion created a constitutional right to effective counsel in all collateral hearings.

Reactions

Following the decision, the American Bar Association, which had submitted an amicus brief in the case, stated "this welcome decision is in accord with longstanding policy of the American Bar Association" and claimed that this "significant ruling will help ensure fairness and justice for many criminal defendants throughout the country." [1] [8]

See also

Related Research Articles

<span class="mw-page-title-main">Appellate procedure in the United States</span> National rules of court appeals

United States appellate procedure involves the rules and regulations for filing appeals in state courts and federal courts. The nature of an appeal can vary greatly depending on the type of case and the rules of the court in the jurisdiction where the case was prosecuted. There are many types of standard of review for appeals, such as de novo and abuse of discretion. However, most appeals begin when a party files a petition for review to a higher court for the purpose of overturning the lower court's decision.

A writ of coram nobis is a legal order allowing a court to correct its original judgment upon discovery of a fundamental error that did not appear in the records of the original judgment's proceedings and that would have prevented the judgment from being pronounced. The term coram nobis is Latin for "before us" and the meaning of its full form, quae coram nobis resident, is "which [things] remain in our presence". The writ of coram nobis originated in the courts of common law in the English legal system during the sixteenth century.

In United States law, ineffective assistance of counsel (IAC) is a claim raised by a convicted criminal defendant asserting that the defendant's legal counsel performed so ineffectively that it deprived the defendant of the constitutional right guaranteed by the Assistance of Counsel Clause of the Sixth Amendment to the United States Constitution. Ineffectiveness claims may only be brought where the defendant had the right to counsel, ordinarily during the critical stages of a prosecution.

Actual innocence is a special standard of review in legal cases to prove that a charged defendant did not commit the crimes that they were accused of, which is often applied by appellate courts to prevent a miscarriage of justice.

Day v. McDonough, 547 U.S. 198 (2006), is a US Supreme Court case involving the one-year statute of limitations for filing habeas corpus petitions that was established by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). In a 5–4 decision, the Court ruled that if the government unintentionally failed to object to the filing of a petition after the AEDPA limitations period has expired, it is not an abuse of discretion for a district court to dismiss sua sponte the petition on that basis.

<span class="mw-page-title-main">2005 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down sixteen per curiam opinions during its 2005 term, which lasted from October 3, 2005, until October 1, 2006.

<span class="mw-page-title-main">2004 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down six per curiam opinions during its 2004 term, which began October 4, 2004 and concluded October 3, 2005.

House v. Bell, 547 U.S. 518 (2006), is a United States Supreme Court case challenging the permissibility of new DNA forensic evidence that becomes available post-conviction, in capital punishment appeals when those claims have defaulted pursuant to state law. The Court found that admitting new DNA evidence was in line with Schlup v. Delo (1995), which allows cases to be reopened in light of new evidence.

Strickland v. Washington, 466 U.S. 668 (1984), was a landmark Supreme Court case that established the standard for determining when a criminal defendant's Sixth Amendment right to counsel is violated by that counsel's inadequate performance.

Padilla v. Commonwealth of Kentucky, 559 U.S. 356 (2010), is a case in which the United States Supreme Court decided that criminal defense attorneys must advise noncitizen clients about the deportation risks of a guilty plea. The case extended the Supreme Court's prior decisions on criminal defendants' Sixth Amendment right to counsel to immigration consequences.

Artuz v. Bennett, 531 U.S. 4 (2000), was a unanimously-decided United States Supreme Court case. The case concerned whether a habeas corpus petition tolled for time under the Antiterrorism and Effective Death Penalty Act of 1996 when certain state claims are still pending. The Court held that the petition did not toll.

Premo v. Moore, 562 U.S. 115 (2011), is a United States Supreme Court case involving the right of individuals to federal habeas corpus relief on state-law claims. In a unanimous ruling, the court held that habeas relief may not be granted with respect to any claim that a state-court has found on the merits unless the state-court decision denying relief involves an "unreasonable application" of "clearly established federal law, as determined by" the Court.

Davis v. Ayala, 576 U.S. 257 (2015), was a case in which the Supreme Court of the United States upheld a death sentence of a Hispanic defendant despite the fact that all Blacks and Hispanics were rejected from the jury during the defendant's trial. The case involved a habeas corpus petition submitted by Hector Ayala, who was arrested and tried in the late 1980s for the alleged murder of three individuals during an attempted robbery of an automobile body shop in San Diego, California in April 1985. At trial, the prosecution used peremptory challenges to strike all Black and Hispanic jurors who were available for jury service. The trial court judge allowed the prosecution to explain the basis for the peremptory challenges outside the presence of Ayala's counsel, "so as not to disclose trial strategy". Ayala was ultimately sentenced to death, but he filed several appeals challenging the constitutionality of the trial court's decision to exclude his counsel from the hearings.

Fundamental error is a legal term provided by United States Courts to describe an error which occurs whenever a judgement violates a federal fundamental right. In United States constitutional law, fundamental rights have special significance under the U.S. Constitution. Those rights enumerated in the U.S. Constitution are recognized as "fundamental" by the U.S. Supreme Court. State courts within the United States may define fundamental error rules independently of the federal courts. State fundamental error rules may include errors which violate rights in additional to those rights guaranteed by the U.S. Constitution, but these rules may not infringe upon federal fundamental rights. Any law restricting such a right must both serve a compelling state purpose and be narrowly tailored to that compelling purpose.

Bell v. Cone, 535 U.S. 685 (2002), was a Supreme Court of the United States case that upheld a death sentence despite the defendant's argument that he should not be sentenced to death because he was suffering from drug-induced psychosis when he committed the crimes. Cone also argued that he was denied effective assistance of counsel because his attorney failed to present sufficient mitigating evidence during the sentencing phase of his trial and that his attorney inappropriately waived his final argument during the sentencing phase. In an 8–1 opinion written by Chief Justice William Rehnquist, the United States Supreme Court denied Cone's petition for a writ of habeas corpus. The Court held that the actions taken by Cone's attorney during the sentencing phase were "tactical decisions" and that the state courts that denied Cone's appeals did not unreasonably apply clearly established law. Justice John Paul Stevens wrote a dissenting opinion in which he argued that Cone was denied effective assistance of counsel because his attorney failed to "subject the prosecution's case to meaningful adversarial testing."

Lafler v. Cooper, 566 U.S. 156 (2012), was a United States Supreme Court case in which the Court clarified the Sixth Amendment standard for reversing convictions due to ineffective assistance of counsel during plea bargaining. The Court ruled that when a lawyer's ineffective assistance leads to the rejection of a plea agreement, a defendant is entitled to relief if the outcome of the plea process would have been different with competent advice. In such cases, the Court ruled that the Sixth Amendment requires the trial judge to exercise discretion to determine an appropriate remedy.

Kimmelman v. Morrison, 477 U.S. 365 (1986), was a decision of the U.S. Supreme Court that clarified the relationship of the right to effective assistance of counsel under the Sixth Amendment to other constitutional rights in criminal procedure. In this case, evidence against the defendant was probably seized illegally, violating the Fourth Amendment, but he lost the chance to argue that point due to his lawyer's ineffectiveness. The prosecution argued that the defendant's attempt to make a Sixth Amendment argument via a habeas corpus petition was really a way to sneak his Fourth Amendment argument in through the back door. The Court unanimously disagreed, and held that the Fourth Amendment issue and the Sixth Amendment issue represented different constitutional values, and had different requirements for prevailing in court, and therefore were to be treated separately by rules of procedure. Therefore, the habeas corpus petition could go forward. In its opinion, the Court also gave guidance on how to apply its decisions in Stone v. Powell and Strickland v. Washington.

Shinn v. Ramirez, 596 U.S. ___ (2022), was a case decided by the United States Supreme Court related to the Antiterrorism and Effective Death Penalty Act of 1996. The court held that new evidence that was not in the state court's records, based on ineffective assistance of post-conviction counsel, could not be used in an appeal to a federal court.

Cruz v. Arizona, 598 U.S. 17 (2023), was a United States Supreme Court case related to habeas corpus.

Cullen v. Pinholster, 563 U.S. 170, is a 2011 United States Supreme Court case concerning evidentiary development in federal habeas corpus proceedings. Oral arguments in the case took place on November 9, 2010, and the Supreme Court issued its decision on April 4, 2011. The Supreme Court held 5–4 that only evidence originally presented before the state court in which the claim was originally adjudicated on the merits could be presented when raising a claim under 28 U.S.C. § 2254(d)(1), and that evidence from a federal habeas court could not be presented in such proceedings. It also held that the convicted murderer Scott Pinholster, the respondent in the case, was not entitled to the habeas relief he had been granted by the United States Court of Appeals for the Ninth Circuit.

References

  1. 1 2 3 4 Weiss, Debra Cassens (March 20, 2012). "Supreme Court Rules for Inmate With Double Claims of Ineffective Assistance; Scalia Detects a 'Sham'". ABA Journal. Retrieved May 27, 2022.
  2. 1 2 Vladeck, Steve (September 29, 2011). "Martinez v. Ryan argument preview: Direct vs. collateral review and the theory behind the right to counsel". SCOTUSBlog. Retrieved May 27, 2022.
  3. 1 2 3 4 5 6 7 8 9 Hsieh, Sylvia (June 6, 2011). "U.S. Supreme Court has agreed to decide: Does a defendant have right to effective assistance in postconviction proceeding?". Lawyers USA.
  4. Vladeck, Steve (October 5, 2011). "Argument recap: An Arizona-specific right to collateral post-conviction counsel?". SCOTUSBlog. Retrieved May 27, 2022.
  5. 1 2 3 "Martinez v. Ryan". SCOTUSBlog . Retrieved May 27, 2022.
  6. Biale, Noam (May 23, 2022). "Conservative majority hollows out precedent on ineffective-counsel claims in federal court". SCOTUSBlog. Retrieved May 27, 2022.
  7. Vladeck, Steve (March 21, 2012). "Opinion analysis: A new remedy, but no right". SCOTUSBlog. Retrieved May 27, 2022.
  8. "ABA APPLAUDS U.S. SUPREME COURT DECISION IN MARTINEZ V. RYAN". States News Service. March 20, 2012.