Shinn v. Ramirez

David Ramirez and Barry Jones (defendants) were convicted of separate murders in separate Arizona trials. The Arizona Supreme Court affirmed both men’s convictions, and each man filed a state habeas petition. Ramirez’s state postconviction counsel omitted a claim that Ramirez’s trial counsel provided ineffective assistance of counsel by failing to obtain and present evidence that Ramirez might have intellectual disabilities. Ramirez filed a second habeas petition that raised the missing claim, but it was summarily denied as untimely under state law. Ramirez then filed a federal habeas petition. The district court initially held that Ramirez’s failure to timely raise his ineffective-assistance claim at the state level resulted in the procedural default of his federal habeas claim. Ramirez argued that the district court should forgive the procedural default because, by failing to assert the ineffective-assistance-of-trial-counsel claim, Ramirez’s state postconviction attorney was ineffective. The district court agreed to hear new evidence in support of Ramirez’s argument and excused the procedural default but rejected Ramirez’s ineffective-assistance claim on the merits. The Ninth Circuit reversed and remanded for further factfinding. Jones’s state postconviction counsel made a similar error, omitting a claim that Jones’s trial counsel had been ineffective by failing to uncover and introduce exculpatory evidence. The state habeas petition was summarily denied, and Jones filed a federal habeas petition. The district court found that Jones’s ineffective-assistance claim was procedurally defaulted but later allowed Jones to present additional evidence to support his petition. The court relied on this new evidence to conclude that Jones’s trial counsel provided ineffective assistance. Arizona appealed, arguing that the district court should not have heard new evidence. The Ninth Circuit affirmed, holding that the new evidence was permissible because Jones’s postconviction counsel was ineffective for failing to develop the record concerning the ineffective assistance of trial counsel. The United States Supreme Court granted certiorari in both cases.