Martinez v. Ryan
United States Supreme Court
566 U.S. 1, 132 S. Ct. 1309, 182 L. Ed. 2d 272 (2012)
- Written by Arlyn Katen, JD
Facts
Luis Martinez (defendant) was sentenced to two consecutive life imprisonment terms for two counts of sexual conduct with a minor under age 15. Martinez’s court-appointed appellate counsel represented him in a direct appeal, and although counsel also initiated Martinez’s first collateral proceeding, counsel later informed the court that she found no colorable claims for Martinez’s collateral appeal. The court dismissed the first collateral proceeding. Martinez initiated his second collateral proceeding through different counsel and raised ineffective-assistance-of-trial-counsel (IATC) claims for the first time. Arizona courts dismissed that second collateral proceeding, finding that Martinez’s IATC claims were untimely. Martinez then filed a federal habeas petition, but the district court denied Martinez’s habeas petition, and the United States Court of Appeals for the Ninth Circuit affirmed, finding that Martinez’s IATC claims were procedurally defaulted. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Kennedy, J.)
Dissent (Scalia, J.)
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