Keeney v. Tamayo-Reyes

In 1984, Jose Tamayo-Reyes (defendant) was accused of stabbing and killing a man. Tamayo-Reyes was a Cuban immigrant with limited schooling and virtually no English proficiency, so the trial court provided an interpreter to him. Tamayo-Reyes’s court-appointed attorney recommended that Tamayo-Reyes plead nolo contendere to first-degree manslaughter. Tamayo-Reyes signed an English-language plea form that explained the rights he waived by entering a plea. The judge then verbally explained the waiver of rights through the interpreter. After Tamayo-Reyes indicated that he understood his rights, the judge accepted his nolo contendere plea to first-degree manslaughter. Tamayo-Reyes later challenged his plea in collateral state-court proceedings. Tamayo-Reyes argued that (1) his plea was not knowing and intelligent because the translator did not accurately translate the mens rea element of manslaughter and (2) he did not understand the purpose of the plea form or plea hearing and instead believed that he was agreeing to proceed to trial for manslaughter. After the state courts rejected these claims, Tamayo-Reyes filed a habeas petition in federal district court. The district court denied Tamayo-Reyes’s petition, holding that through inexcusable neglect, Tamayo-Reyes had failed to develop key facts relevant to his claim and was not entitled to an evidentiary hearing. The United States Court of Appeals for the Ninth Circuit reversed the district court, finding that Tamayo-Reyes’s counsel negligently failed to develop appropriate facts and that the failure did not reflect Tamayo-Reyes’s intent to deliberately bypass state-court procedure. The United States Supreme Court granted certiorari.