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Divided court restricts prisoners’ ability to pursue claims that their lawyers were incompetent

Two men on Arizona’s death row are not entitled to present new evidence in federal court to support their arguments that their trial lawyers bungled their cases, the Supreme Court ruled Monday in a 6-3 decision.

The question in Shinn v. Ramirez and Jones was whether state prisoners challenging their convictions and sentences in federal court could develop evidence in the federal proceeding to support claims that their state trial lawyers were ineffective to such a degree that the prisoners’ Sixth Amendment right to counsel was compromised. The case pitted the language of the Anti-Terrorism and Effective Death Penalty Act of 1996, which generally prohibits federal courts from holding an evidentiary hearing on these kinds of claims if the prisoner “has failed to develop the factual basis of a claim in State court proceedings,” against a 2012 Supreme Court decision, Martinez v. Ryan, which held that prisoners can raise a claim of ineffective assistance of counsel for the first time in federal court.

David Martinez Ramirez and Barry Lee Jones, both of whom were sentenced to death in Arizona, argued that rigid application of the statute would lead to the absurd result of prisoners being able to raise a claim, but not to develop any evidence to support it, undermining the rationale of Martinez. Arizona argued that where a decision of the court and a congressional statute conflict, the tie must go to Congress.

In an opinion by Justice Clarence Thomas, the court sided with Arizona.

“[O]nly rarely may a federal habeas court hear a claim or consider evidence that a prisoner did not previously present to the state courts in compliance with state procedural rules,” Thomas wrote. And in this case, he concluded, Section 2254(e)(2) forecloses the prisoners’ efforts to introduce new evidence outside the state-court record.

The three liberal justices dissented.

“The Court’s decision,” Justice Sonia Sotomayor wrote for the trio, “will leave many people who were convicted in violation of the Sixth Amendment to face incarceration or even execution without any meaningful chance to vindicate their right to counsel.”

Check back soon for in-depth analysis of the opinion.

Recommended Citation: Noam Biale, Divided court restricts prisoners’ ability to pursue claims that their lawyers were incompetent, SCOTUSblog (May. 23, 2022, 12:40 PM),