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Keywords

attorneyappealtrialpro bono
attorneyappealtrialpro bono

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Maples v. Thomas, 565 U.S. 266, 132 S.Ct. 912, 181 L.Ed.2d 807, 80 USLW 4086, 12 Cal. Daily Op. Serv. 677, 2012 Daily Journal D.A.R. 636, 23 Fla. L. Weekly Fed. S 86

Facts

Cory R. Maples was convicted of capital murder in Alabama and sentenced to death. After his conviction was affirmed, he sought postconviction relief, alleging ineffective assistance of counsel. His pro bono attorneys left their firm without notifying him, and as a result, he was left without representation during the critical 42-day period to appeal the trial court's denial of his petition. The trial court's notices were sent to his former attorneys, who did not receive them, and no action was taken on his behalf, leading to a missed appeal deadline.

Cory R. Maples was convicted of capital murder in Alabama and sentenced to death. After his conviction was affirmed, he sought postconviction relief, alleging ineffective assistance of counsel. His pro bono attorneys left their firm without notifying him, and as a result, he was left without representation during the critical 42-day period to appeal the trial court's denial of his petition.

Issue

Whether Maples had shown sufficient cause to excuse his procedural default in failing to file a timely notice of appeal from the trial court's denial of his postconviction relief petition.

Whether Maples had shown sufficient cause to excuse his procedural default in failing to file a timely notice of appeal from the trial court's denial of his postconviction relief petition.

Rule

A federal court may not entertain a state prisoner's habeas claims if a state court has declined to address those claims due to the prisoner's failure to meet a state procedural requirement, unless the prisoner can demonstrate cause for the procedural default and actual prejudice as a result of the alleged violation of federal law.

A federal court may not entertain a state prisoner's habeas claims if a state court has declined to address those claims due to the prisoner's failure to meet a state procedural requirement, unless the prisoner can demonstrate cause for the procedural default and actual prejudice as a result of the alleged violation of federal law.

Analysis

The Court found that Maples' attorneys had effectively abandoned him without notice, severing the principal-agent relationship. This abandonment meant that Maples could not be held responsible for the failure to comply with the procedural rule requiring a timely appeal. The Court emphasized that the lack of representation during the critical period constituted sufficient cause to excuse the procedural default.

The Court found that Maples' attorneys had effectively abandoned him without notice, severing the principal-agent relationship. This abandonment meant that Maples could not be held responsible for the failure to comply with the procedural rule requiring a timely appeal.

Conclusion

The Supreme Court reversed the Eleventh Circuit's judgment, holding that Maples had shown the requisite cause to excuse his procedural default. The case was remanded for further proceedings to address the question of prejudice.

The Supreme Court reversed the Eleventh Circuit's judgment, holding that Maples had shown the requisite cause to excuse his procedural default.

Who won?

Cory R. Maples prevailed in the Supreme Court, as the Court recognized that he had been abandoned by his attorneys and thus could not be held accountable for the missed appeal deadline.

Cory R. Maples prevailed in the Supreme Court, as the Court recognized that he had been abandoned by his attorneys and thus could not be held accountable for the missed appeal deadline.

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