Martinez v. Ryan
| Martinez v. Ryan | |
|---|---|
| Argued October 4, 2011 Decided March 20, 2012 | |
| Full case name | Luis Mariano Martinez v. Charles L. Ryan, Director, Arizona Department of Corrections |
| Docket no. | 10-1001 |
| Citations | 566 U.S. 1 (more) 132 S. Ct. 1309; 182 L. Ed. 2d 272 |
| Argument | Oral argument |
| Case history | |
| Prior | Martinez v. Schriro, 623 F.3d 731 (9th Cir. 2010) |
| Subsequent | Martinez v. Ryan, 680 F.3d 1160 (9th Cir. 2012) |
| Court membership | |
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| Case opinions | |
| Majority | Kennedy, joined by Roberts, Ginsburg, Breyer, Alito, Sotomayor, and Kagan |
| Dissent | Scalia, joined by Thomas |
Martinez v. Ryan, 566 U.S. 1 (2012) was a United States Supreme Court case that created a small exception to a previous ruling, Coleman v. Thompson. Normally, if a prisoner misses a deadline to file an appeal under state law, federal courts can’t review their case—even if their lawyer made a mistake. Coleman had ruled that ineffective assistance of counsel during appeals doesn’t excuse this kind of procedural default.
However, the Martinez decision said that in very specific situations—where state law requires prisoners to raise claims of ineffective lawyers after their trial and doesn’t provide them with proper legal help—then a federal court can still hear their case. This exception applies only if the prisoner never got a real chance to fairly argue their constitutional claim.