Murray v. Carrier

Summary

The Court held that counsel's inadvertent failure to raise a claim on appeal does not establish cause excusing a state procedural default unless the error constitutes constitutionally ineffective assistance. Cause ordinarily requires an objective impediment external to the defense, and an ineffective-assistance claim generally must first be exhausted in state court before serving as cause. Actual prejudice alone does not excuse the absence of cause, but an extraordinary case involving a constitutional violation that probably convicted an actually innocent person permits review without cause. The Court reversed and remanded for consideration of whether the withheld statements established Carrier's actual innocence. Stevens, joined by Blackmun, concurred in the judgment, favoring a broader inquiry into fundamental fairness and declining to endorse the newly announced innocence standard. Brennan, joined by Marshall, dissented, arguing that counsel's inadvertence should establish cause and that the Court of Appeals should be affirmed.