Trevino v. Thaler (2012)
- Docket
- 11-10189
- Decided
- 2012-01-01
Summary
Question: Can the ineffective assistance of a criminal defendant's counsel during state habeas proceedings excuse his failure to properly claim ineffective assistance earlier in the proceedings? Conclusion: Yes. Justice Stephen G. Breyer delivered the opinion for the 5-4 majority. The Court vacated the lower courts' decisions and held that a procedural default will not bar a federal court from hearing a claim of ineffective assistance of trial counsel. The Court upheld a previous precedent established in Martinez v. Ryan that stated that an attorney's ignorance in a post-conviction hearing did not qualify as a reason to excuse a procedural default ruling. Because Texas' law made it virtually impossible for a defendant to present an ineffective assistance of counsel claim during an appeal, it was highly unlikely that a typical defendant could raise a claim of ineffective assistance of counsel Chief Justice John Roberts, joined by Justice Samuel A. Alito, Jr., dissented, and argued that the rule established in Martinez was specifically designed to be applied in a very narrow fashion and that the majority's opinion represented an inconsistent expansion of that holding. Justice Antonin Scalia, joined by Justice Clarence Thomas, wrote a separate dissent in which he argued the rulings in both this case and Martinez drastically altered habeas corpus jurisprudence without providing clear benefits to the judicial process.