Coyle v. State

Summary

The Supreme Court of Maryland held that when the Office of the Public Defender authorizes a panel attorney to file a certiorari petition, the attorney must provide effective assistance under the Maryland Public Defender Act, even though the Court did not decide whether the Act independently creates a right to counsel at that stage. Counsel performed deficiently by failing to file the authorized petition, and prejudice was established because the failure deprived Coyle of the opportunity to have the petition considered, without requiring proof that review would have been granted. The Court reversed and permitted Coyle to file a belated petition for a writ of certiorari.