Erick Daniel Davila, Petitioner v. Lorie Davis

Summary

The Supreme Court held that the narrow equitable exception announced in Martinez v. Ryan and clarified in Trevino v. Thaler does not extend to procedurally defaulted claims of ineffective assistance of appellate counsel; a prisoner whose state postconviction counsel ineffectively failed to raise such a claim cannot use that ineffectiveness as cause to excuse the default, and the rule of Coleman v. Thompson continues to govern. The Court reasoned that Martinez is confined by its text and rationale to substantial claims of ineffective assistance of trial counsel that States channel into initial-review collateral proceedings, that appellate-ineffectiveness claims necessarily arise in collateral proceedings by their nature rather than by state design, and that extension would flood the federal courts, produce a domino effect exposing nearly any defaulted trial error to review, and aggravate federalism costs for an infinitesimally small systemic benefit. The Fifth Circuit's denial of relief was affirmed. Justice Breyer, joined by Justices Ginsburg, Sotomayor, and Kagan, dissented, arguing that Martinez should apply equally to claims of ineffective assistance of appellate counsel.