Justices limit federal review of lawyers’ effectiveness in criminal cases
The Supreme Court on Monday limited the power of federal courts to review claims by convicted defendants who say they received inadequate legal counsel in state court proceedings, in a ruling with profound implications for some inmates seeking exoneration.
The 6-3 decision broke along familiar lines, with the court’s conservatives forming a majority over the dissent of the court’s three most liberal members.
The decision handed a defeat to two Arizona death row inmates. The justices ruled that because the defendants failed to present evidence in state court demonstrating the ineffectiveness of their trial lawyers, they were barred from doing so in federal court.
The Monday decision rejected the inmates’ argument that they should be granted an exception to this rule since their failure to present the evidence was the result of yet another round of inadequate lawyering following their convictions.
Justice Clarence Thomas, writing for the conservative majority, said that permitting the sort of leniency sought by the defendants would give a federal court reviewing habeas claims too much authority, at the expense of state courts that should have final say over such cases.
“To respect our system of dual sovereignty, the availability of habeas relief is narrowly circumscribed,” Thomas said, adding that only in rare post-conviction cases can federal courts “hear a claim or consider evidence that a prisoner did not previously present to the state courts.”
In a dissent that was joined by the court’s other two liberals, Justice Sonia Sotomayor called the ruling “perverse” and “illogical.”
“Contrary to the Court’s account, the fundamental fairness concerns that arise from this particular type of breakdown are not unconditionally eclipsed by the need to accord finality and respect to state-court judgments,” she wrote. “Neither statute nor precedent supports the Court’s assertion that the virtues of finality override fundamental fairness to such a degree that meaningful review of life-or-death judgments obtained through such deeply flawed proceedings should be foreclosed.”
The defendants include David Martinez Ramirez, who was convicted of a double murder in 1989. Ramirez later claimed his trial lawyer erred by failing to present evidence of his intellectual disability.
The other defendant, Berry Lee Jones, was convicted in 1995 for the murder and sexual assault of his girlfriend’s 4-year-old daughter. He later claimed his trial lawyer failed to adequately investigate key evidence, including the police handling of his case, medical evidence and a timeline of the injuries and death.
Both men subsequently claimed in federal court that their post-conviction legal counsel was at fault for failing to advance the argument that they’d received inadequate representation at trial.
Arizona appealed to the Supreme Court after a lower federal appeals court sided with some of the defendants’ claims.
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