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Shinn v. Ramirez

Shinn v. Ramirez

Supreme Court of the United States

December 8, 2021, Argued; May 23, 2022, Decided1

No. 20-1009.

Opinion

Justice Thomas delivered the opinion of the Court.

A federal habeas court generally may consider a state prisoner’s federal claim only if he has first presented that claim to the state court in accordance with state procedures. When the prisoner has failed to do so, and the state court would dismiss the claim on that basis, the claim is “procedurally defaulted.” To overcome procedural default, the prisoner must demonstrate “cause” to excuse the procedural defect and “actual prejudice” if the federal court were to decline to hear his claim. Coleman v. Thompson, 501 U. S. 722, 750, 111 S. Ct. 2546, 115 L. Ed. 2d 640 (1991). In Martinez v. Ryan, 566 U. S. 1, 132 S. Ct. 1309, 182 L. Ed. 2d 272 (2012), this Court explained that ineffective assistance of postconviction counsel is “cause” to forgive procedural default of an ineffective-assistance-of-trial-counsel claim, but only if the State required the prisoner to raise that claim for the first time during state postconviction proceedings.

Often, a prisoner with a defaulted claim will ask a federal habeas court not only to consider his claim but also to permit him to introduce new evidence to support it. Under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), the standard to expand the state-court record is a stringent one. If a prisoner has “failed to develop the factual basis [*10]  of a claim in State court proceedings,” a federal court “shall not hold an evidentiary hearing on the claim” unless the prisoner satisfies one of two narrow exceptions, see 28 U. S. C. §2254(e)(2)(A), and demonstrates that the new evidence will establish his innocence “by clear and convincing evidence,” §2254(e)(2)(B). In all but these extraordinary cases, AEDPA “bars evidentiary hearings in federal habeas proceedings initiated by state prisoners.” McQuiggin v. Perkins, 569 U. S. 383, 395, 133 S. Ct. 1924, 185 L. Ed. 2d 1019 (2013).

The question presented is whether the equitable rule announced in Martinez permits a federal court to dispense with §2254(e)(2)’s narrow limits because a prisoner’s state postconviction counsel negligently failed to develop the state-court record. We conclude that it does not.

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2022 U.S. LEXIS 2557 *; __ S.Ct. __; 2022 WL 1611786

DAVID SHINN, DIRECTOR, ARIZONA DEPARTMENT OF CORRECTIONS, REHABILITATION AND REENTRY, PETITIONER v. DAVID MARTINEZ RAMIREZ

Notice: The pagination of this document is subject to change pending release of the final published version.

Prior History:  [*1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

Jones v. Shinn, 943 F.3d 1211, 2019 U.S. App. LEXIS 35708, 2019 WL 6442931 (9th Cir. Ariz., Nov. 29, 2019)Ramirez v. Ryan, 937 F.3d 1230, 2019 U.S. App. LEXIS 27370, 2019 WL 4281731 (9th Cir. Ariz., Sept. 11, 2019)

Disposition: 937 F. 3d 1230 and 943 F. 3d 1211, reversed.

CORE TERMS

postconviction, state court, federal court, ineffective assistance, procedural default, state-court, trial-ineffectiveness, ineffective, fault, district court, evidentiary hearing, trial counsel, proceedings, defaulted, diligence, habeas petitioner, attorney error, factual basis, habeas relief, quotation, cases, marks, evidentiary, convicted, postconviction proceedings, new evidence, trial-ineffective-assistance, state prisoner, courts, investigate

Constitutional Law, Fundamental Rights, Criminal Process, Assistance of Counsel, Criminal Law & Procedure, Exceptions to Default, Cause & Prejudice Standard, Proof of Cause, Proof of Prejudice, Habeas Corpus, Review, Scope of Review, Evidence, Burdens of Proof, Clear & Convincing Proof, Governments, Courts, Judicial Comity, Congressional Duties & Powers, Reserved Powers, Lower Federal Courts, Authority to Adjudicate, Civil Procedure, Writs, Common Law Writs, Mandamus, Justiciability, Exhaustion of Remedies, Administrative Remedies, Order & Timing of Petitions, Procedural Default, Procedural Defenses, Failure to Exhaust Remedies, Failure to Exhaust, Exceptions, Procedure, Specific Claims, Ineffective Assistance of Counsel, Judicial Officers, Judges, Discretionary Powers, The Judiciary, Congressional Limits, Counsel, Right to Counsel, Postconviction, Pretrial Judgments, Default & Default Judgments, Relief From Default