Maples v. Thomas

Summary

The Supreme Court held that an Alabama death-row prisoner who missed the State's 42-day deadline for appealing the denial of his Rule 32 postconviction petition demonstrated 'cause' excusing that procedural default, because his attorneys of record had abandoned him without notice: the two departing pro bono New York lawyers severed their agency relationship without telling him or withdrawing, the other firm lawyers lacked authority to act, and local counsel never functioned as his agent, leaving him unaware he had been reduced to pro se status. Applying agency principles within the established cause-and-prejudice framework, the Court reasoned that a client cannot be charged with the acts or omissions of an attorney who has ceased acting as his agent, while preserving the general rule that postconviction counsel's negligence does not qualify as cause. Because neither court below reached the prejudice question, it remains open on remand. Justice Alito concurred, attributing the default to a unique 'perfect storm' of eight events rather than any defect in Alabama's representation system; Justice Scalia, joined by Justice Thomas, dissented, contending that other firm lawyers and admitted local counsel remained Maples' agents so the default was chargeable attorney error.