## Facts

- Cory R. Maples was convicted of capital murder in Alabama and sentenced to death; his conviction and sentence were affirmed on direct review.
- Maples filed a state postconviction petition (Rule 32) alleging, among other claims, ineffective assistance of trial counsel.
- Two out-of-state pro bono attorneys entered appearances; an in-state attorney agreed to serve only as a nominal sponsor for their pro hac vice admission and undertook no substantive role.
- While the Rule 32 petition was pending, the two pro bono attorneys left their firm and became unable to continue representing Maples, but they did not notify Maples, did not seek leave to withdraw, and no replacement counsel entered an appearance.
- The state trial court denied Rule 32 relief; notice was mailed to the two pro bono attorneys at their former firm, returned unopened as undeliverable, and the clerk made no further effort to notify Maples.
- The in-state nominal attorney received the order but did not file a notice of appeal.
- The 42-day deadline to appeal the Rule 32 denial expired without any appeal being filed; later efforts to obtain an out-of-time appeal were rejected by Alabama courts.

## Issues

1. Whether, in federal habeas proceedings, postconviction counsel’s abandonment of a prisoner—effectively severing the attorney-client relationship without notice—constitutes “cause” to excuse a state procedural default for failure to timely appeal a denial of postconviction relief.

## Decision

- The Supreme Court held that Maples established “cause” to excuse the procedural default.
- The Court vacated the judgment of the Eleventh Circuit and remanded for further proceedings.
- The Court distinguished ordinary attorney negligence (generally attributable to the client) from abandonment that leaves no functioning attorney-agent to act for the client.
- The Court concluded that the abandonment, combined with Maples’s lack of notice and inability to protect himself pro se, was an objective external factor that impeded compliance with the state deadline.

## Legal Principles

- A federal habeas petitioner may overcome a state procedural default by showing “cause” and prejudice; “cause” requires an objective factor external to the defense that prevented compliance with the state procedural rule.
- Under agency principles applied in procedural-default doctrine, attorney negligence in postconviction litigation is ordinarily imputed to the client and does not constitute “cause.”
- When counsel abandons the client such that the attorney-client relationship is effectively severed and no attorney can be expected to act on the client’s behalf, the failure to comply with a procedural rule is not fairly attributable to the client and may constitute “cause.”
- The “abandonment” basis for cause is limited and does not create a general right to effective counsel in state postconviction proceedings.

## Conclusion

The Court ruled that a death-sentenced prisoner may show “cause” to excuse a procedural default when postconviction counsel effectively abandons the representation without notice, leaving the prisoner unrepresented at a critical time and unable to take timely action to preserve appellate review.


Maples v. Thomas, 565 U.S. 266 (2012)