Shinn v. Ramirez
Decision Date | 23 May 2022 |
Docket Number | 20-1009 |
Parties | DAVID SHINN, DIRECTOR, ARIZONA DEPARTMENT OF CORRECTIONS, REHABILITATION AND REENTRY, PETITIONER v. DAVID SHINN, DIRECTOR, ARIZONA DEPARTMENT OF CORRECTIONS, REHABILITATION AND REENTRY, ET AL., PETITIONERS DAVID MARTINEZ RAMIREZ v. BARRY LEE JONES |
Court | U.S. Supreme Court |
Respondents David Martinez Ramirez and Barry Lee Jones were each convicted of capital crimes in Arizona state court and sentenced to death. The Arizona Supreme Court affirmed each case on direct review, and each prisoner was denied state postconviction relief. Each also filed for federal habeas relief under 28 U.S.C. §2254, arguing that trial counsel had been ineffective for failing to conduct adequate investigations. The Federal District Court held in each case that the prisoner's ineffective-assistance claim was procedurally defaulted because it was not properly presented in state court. To overcome procedural default in such cases a prisoner must demonstrate "cause" to excuse the procedural defect and "actual prejudice." Coleman v. Thompson, 501 U.S. 722, 750. To demonstrate cause, Ramirez and Jones relied on Martinez v. Ryan, 566 U.S. 1, which held that ineffective assistance of postconviction counsel may be cited as cause for the procedural default of an ineffective-assistance-of-trial-counsel claim. In Ramirez's case, the District Court permitted him to supplement the record with evidence not presented in state court to support his case to excuse the procedural default. Assessing the new evidence, the court excused the procedural default but rejected Ramirez's ineffective-assistance claim on the merits. The Ninth Circuit reversed and remanded for more evidentiary development to litigate the merits of Ramirez's ineffective-assistance-of-trial-counsel claim. In Jones' case, the District Court held a lengthy evidentiary hearing on "cause" and "prejudice," forgave his procedural default, and held that his state trial counsel had provided ineffective assistance. The State of Arizona petitioned this Court in both cases, arguing that §2254(e)(2) does not permit a federal court to order evidentiary development simply because postconviction counsel is alleged to have negligently failed to develop the state-court record.
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