Martinez v. Ryan (2011)
- Docket
- 10-1001
- Decided
- 2011-01-01
Summary
Question: May a defendant in a state criminal case who is prohibited by state law from raising on direct appeal any claim of ineffective assistance of trial counsel, but who has a state-law right to raise such a claim in a first post-conviction proceeding, establish cause for a procedural default of a claim of ineffective assistance at trial by showing ineffective assistance at the initial-review collateral proceeding? Conclusion: Yes. In a 7-2 decision written by Justice Anthony Kennedy, the Court carved out an exception to its holding in Coleman v. Thompson , which held that attorney errors in post-conviction hearings do not qualify as cause to excuse procedural defaults. Justice Kennedy declined to answer whether this exception was required by the Constitution. Instead, he distinguished the initial-review collateral hearing from other postconviction review hearings because in the former an attorney's error will likely preclude state courts at any level from further reviewing a prisoner's claims. Justice Kennedy argued that the Court's ruling does not upset stare decisis because the prisoner in Coleman was not claiming ineffective assistance in an initial-review collateral hearing. Justice Antonin Scalia, joined by Justice Clarence Thomas, dissented. He accused the majority of creating a constitutional right to effective counsel in all collateral hearings.