The US Supreme Court [official website] ruled [opinion, PDF] Wednesday in Maples v. Thomas [SCOTUSblog backgrounder] that death row inmate Cory Maples sufficiently established cause excusing the procedural default rule when his attorney left his law firm causing Maples to miss a filing deadline. Maples' attorney argued that he effectively had no local counsel, thus the lack of proper notification to his true counsel, who had never withdrawn, was a clear error. The US Court of Appeals for the Eleventh Circuit had held [JURIST report] the state of Alabama may execute Maples without federal habeas review of his constitutional claims. In a 7-2 decision written by Justice Ruth Bader Ginsburg, the Supreme Court reversed. The court held that Maples was trapped when his counsel abandoned him without warning:
In the unusual circumstances of this case, principles of agency law and fundamental fairness point to the same conclusion: There was indeed cause to excuse Maples' procedural default. Through no fault of his own, Maples lacked the assistance of any authorized attorney during the 42 days Alabama allows for noticing an appeal from a trial court's denial of post conviction relief. As just observed, he had no reason to suspect that, in reality, he had been reduced to pro se status. Maples was disarmed by extraordinary circumstances quite beyond his control.Since the district court and the Eleventh Circuit never reached the question of prejudice, the Supreme Court left the issue open for the lower courts to decide on remand.
An Alabama trial court had dismissed Maples' petition for post-conviction relief and sent notice of this ruling to his out-of-state attorneys, but the notice was returned to the court unopened because the attorneys had changed firms. The court's clerk did not attempt to notify his attorneys again. The clerk did, however, notify Maples' in-state attorney who neither acted nor notified the attorneys who were more directly involved in his case. Maples was convicted of capital murder for killing two people after a night of drinking. He had argued his counsel was ineffective because it failed to present evidence of his intoxication and his drug history, which he believed would have mitigated his sentence. The Supreme Court heard oral arguments [JURIST report] in the case in October.