## Facts

- Luis Mariano Martinez, an Arizona prisoner, was convicted of two counts of sexual conduct with a minor under 15 and sentenced to two consecutive terms of 35 years to life.
- Arizona law required ineffective-assistance-of-trial-counsel claims to be raised in an initial postconviction relief (PCR) proceeding rather than on direct appeal.
- On direct appeal, Martinez’s conviction was affirmed; discretionary review was denied.
- In Martinez’s first PCR proceeding, appointed counsel filed a notice but stated she found no colorable claims and did not raise ineffective assistance of trial counsel.
- The PCR court dismissed the proceeding when no proper petition was filed.
- Martinez later attempted to raise ineffective assistance of trial counsel in state court, but the claim was rejected as procedurally barred under state timeliness and preclusion rules.

## Issues

1. Whether, when state law requires ineffective-assistance-of-trial-counsel claims to be raised in an initial-review collateral proceeding, ineffective assistance (or absence) of counsel in that proceeding can constitute “cause” to excuse procedural default of the trial-counsel-ineffectiveness claim in federal habeas.

## Decision

- The Supreme Court reversed the judgment of the Ninth Circuit and remanded.
- The Court held that, in states channeling trial-counsel-ineffectiveness claims to initial collateral review, procedural default does not bar federal habeas review if, in that initial-review proceeding, the prisoner had no counsel or counsel was ineffective.
- The Court framed the rule as a narrow, equitable exception to the general rule that attorney errors in postconviction proceedings do not establish cause.

## Legal Principles

- A federal habeas court may excuse procedural default under the cause-and-prejudice framework when the default results from no counsel or ineffective counsel in an initial-review collateral proceeding that provides the first opportunity to raise a trial-IAC claim.
- The exception is equitable, not constitutional; it does not create a constitutional right to counsel in state collateral proceedings.
- The exception is limited to defaults occurring at the initial-review collateral stage, not errors in later collateral proceedings or appeals from initial collateral review.
- To obtain relief from default under this rule, the underlying ineffective-assistance-of-trial-counsel claim must be “substantial,” and the initial-review collateral counsel’s deficiency is assessed under the Strickland standard.

## Conclusion

The Court recognized a limited equitable basis for “cause” in federal habeas when a state makes initial collateral review the first forum for trial-counsel-ineffectiveness claims and the prisoner lacked effective counsel at that stage, allowing review of otherwise defaulted, substantial trial-IAC claims.


Martinez v. Ryan, 566 U.S. 1 (2012)