In Coleman v. Thompson, 501 U.S. 722, 115 L. Ed. 2d 640, 111 S. Ct. 2546 (1991) the Supreme Court held that there is no constitutional requirement of effective assistance of counsel in state post-conviction proceedings. This is because there is no right to counsel in state habeas proceedings. See Coleman, 501 U.S. at 757. Coleman sought federal habeas corpus relief because his state appeal of his post-conviction hearing was procedurally barred for filing the notice of appeal too late. Id. at 752. The Supreme Court explained that an attorney's ignorance or inadvertence is not a reason to look past the procedural default of state-court review. Id. at 753. In that instance, the attorney is the defendant's agent, and the defendant bears the risk of the attorney's acts or omissions in furtherance of the litigation. Id. at 753-54.