Maples v. Thomas - 565 U.S. 266, 132 S. Ct. 912 (2012)

Rule:

As a rule, a state prisoner's habeas claims may not be entertained by a federal court when (1) a state court has declined to address those claims because the prisoner had failed to meet a state procedural requirement, and (2) the state judgment rests on independent and adequate state procedural grounds. The bar to federal review may be lifted, however, if the prisoner can demonstrate cause for the procedural default in state court and actual prejudice as a result of the alleged violation of federal law.

Facts:

Petitioner Cory R. Maples was found guilty of murder and sentenced to death in Alabama state court. In 2001, Maples sought postconviction relief in state court under Alabama Rule of Criminal Procedure 32. Maples alleged, among other things, that his underpaid and inexperienced trial attorneys failed to afford him the effective assistance guaranteed by the Sixth Amendment. His petition was written by two pro bono attorneys, Jaasi Munanka and Clara Ingen-Housz, both associated with the New York offices of the Sullivan & Cromwell law firm. As required by Alabama law, the two attorneys engaged an Alabama lawyer, John Butler, to move their admission pro hac vice. Butler made clear, however, that he would undertake no substantive involvement in the case. In 2002, while Maples' state postconviction petition was pending, Munanka and Ingen-Housz left Sullivan & Cromwell. Their new employment disabled them from representing Maples. They did not inform Maples of their departure and consequent inability to serve as his counsel. In disregard of Alabama law, neither sought the trial court's leave to withdraw. No other Sullivan & Cromwell attorney entered an appearance, moved to substitute counsel, or otherwise notified the court of a change in Maples' representation. Thus, Munanka, Ingen-Housz, and Butler remained Maples' listed, and only, attorneys of record. The trial court denied Maples' petition in May 2003. Notices of the order were posted to Munanka and Ingen-Housz at Sullivan & Cromwell's address. When those postings were returned, unopened, the trial court clerk attempted no further mailing. Butler also received a copy of the order, but did not act on it. With no attorney of record in fact acting on Maples' behalf, the 42-day period Maples had to file a notice of appeal ran out. About a month later, an Alabama Assistant Attorney General sent a letter directly to Maples. The letter informed Maples of the missed deadline and notified him that he had four weeks remaining to file a federal habeas petition. Maples immediately contacted his mother, who called Sullivan & Cromwell. Three Sullivan & Cromwell attorneys, through Butler, moved the trial court to reissue its order, thereby restarting the 42-day appeal period. The court denied the motion. The Alabama Court of Criminal Appeals then denied a writ of mandamus that would have granted Maples leave to file an out-of-time appeal, and the State Supreme Court affirmed. Maples sought federal habeas relief. Both the District Court and the Eleventh Circuit denied his request, pointing to the procedural default in state court, i.e., Maples' failure timely to appeal the state trial court's order denying his Rule 32 petition for postconviction relief. Certiorari was granted.

Issue:

Under the circumstances, should Maple’s procedural default in state court be excused?

Answer:

Yes.

Conclusion:

The Supreme Court determined that there was "cause" to excuse the missed notice of appeal deadline because (1) Maples showed that his attorneys of record abandoned him because the New York attorneys' departure from the law firm and their commencement of employment that prevented them from representing him ended their agency relationship with him, other attorneys at the firm had no authority to act for him, and local Alabama counsel did not serve as his agent in any meaningful sense of that word, and (2) he had no reason to suspect that he lacked counsel able and willing to represent him during the time permitted for an appeal. Accordingly, the Court reversed the judgment of the federal appellate court