Martinez v. Ryan

In Martinez v. Ryan, 132 S. Ct. 1309, 182 L. Ed. 2d 272 (2012), the United States Supreme Court recognized an exception to the procedural bar rule that would have otherwise prevented an ineffective assistance of trial counsel claim from being raised in a subsequent proceeding where postconviction counsel failed to raise such a claim with the trial court in the initial-review collateral proceedings. Martinez v. Ryan, addresses a very narrow issue: whether a federal court reviewing a petition filed under 28 U.S.C. 2254 can excuse the procedural default that occurred during state proceedings where a defendant was denied his right to effective assistance of trial counsel and has been unable to raise this claim in the state proceedings because postconviction counsel rendered ineffective assistance in failing to raise the claim in the initial-review collateral proceedings. Id. As the Court has made clear, though, Martinez does not provide an independent basis for relief in state court proceedings. In Martinez, 132 S. Ct. at 1315, the defendant had been unable to raise the denial of his right to effective assistance of trial counsel until federal proceedings began, based on the unique facts and circumstances of the state court proceedings in that case.