Shinn v. Ramirez: Difference between revisions

Shinn v. Ramirez
Shinn v. Ramirez
	Supreme Court of the United States
Argued December 8, 2021; Decided May 23, 2022
Full case name	David Shinn, Director, Arizona Department of Corrections, Rehabilitation and Reentry, et al. v. David Martinez Ramirez and Barry Lee Jones
Docket no.	20-1009
Citations	596 U.S. 366 (more)
Argument	Oral argument
Holding
	Under 28 U.S.C. § 2254(e)(2), a federal habeas court may not conduct an evidentiary hearing or otherwise consider evidence beyond the state-court record based on the ineffective assistance of state postconviction counsel.
Court membership
	Chief Justice John Roberts Associate Justices Clarence Thomas · Stephen Breyer; Samuel Alito · Sonia Sotomayor; Elena Kagan · Neil Gorsuch; Brett Kavanaugh · Amy Coney Barrett
Case opinions
Majority	Thomas, joined by Roberts, Alito, Gorsuch, Kavanaugh, Barrett
Dissent	Sotomayor, joined by Breyer, Kagan
Laws applied
	Antiterrorism and Effective Death Penalty Act of 1996

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Shinn v. Ramirez, 596 U.S. 366 (2022), was a case decided by the United States Supreme Court related to the Antiterrorism and Effective Death Penalty Act of 1996. The court held that new evidence that was not in the state court's records, based on ineffective assistance of post-conviction counsel, could not be used in an appeal to a federal court.

Background

David Ramirez and Barry Jones were convicted of murders in Arizona and sentenced to death in 1989 and 1994, respectively. Ramirez appealed to federal court where his federal public defenders uncovered evidence of intellectual disability and extensive childhood abuse that hadn't been presented at his initial trial. Jones also appealed to federal court, where federal investigators found evidence suggesting he was innocent. In both cases, the new lawyers argued that the failure of the initial public defenders to present evidence that could have been mitigating constituted ineffective counsel.^[1]

In Martinez v. Ryan (2012), the Supreme Court held that prisoners may use post-conviction counsel's ineffectiveness as a reason to overcome procedural default. The United States Court of Appeals for the Ninth Circuit applied Martinez to rule for Ramirez and Jones on their habeas corpus petitions. The Court denied rehearing en banc over the dissent of Judge Daniel P. Collins and seven other judges. Arizona filed a petition for a writ of certiorari.^[2]

Supreme Court

Certiorari was granted in the case on May 17, 2021. On May 23, 2022, the Supreme Court reversed the Ninth Circuit in a 6–3 opinion.

Majority opinion

The majority opinion was authored by Clarence Thomas, and joined by John Roberts, Samuel Alito, Neil Gorsuch, Brett Kavanaugh, and Amy Coney Barrett, the court's six conservative justices.^[3] Thomas stated that allowing claims, like the ones in this case, would cause delays in the future, and cited the brutality of the crimes that were committed.^[4] He also cited a dissent written by the late Justice Antonin Scalia in Martinez, and another dissenting opinion written by Roberts in Trevino v. Thaler (2013), a case that applied Martinez.^[3]

Dissenting opinion

The dissenting opinion was authored by Sonia Sotomayor, and joined by Elena Kagan and Stephen Breyer, the court's three liberal justices.^[5] She described the decision as "perverse" and "illogical".^[6] Sotomayor also attacked the majority opinion's citations of previous dissenting opinions to back up its reasoning. She also hinted that doing so could make the Supreme Court's decision making process appear illegitimate.^[3]

References

^ Totenburg, Nina (May 23, 2022). "Supreme Court hobbles challenges by inmates based on poor legal representation". NPR.
^ Howe, Amy (May 17, 2021). "Court dismisses abortion "gag rule" cases, adds arbitration and habeas cases to docket". SCOTUSblog. Retrieved December 4, 2021.
^ ^a ^b ^c "Conservative majority hollows out precedent on ineffective-counsel claims in federal court". SCOTUSblog. May 23, 2022. Retrieved May 26, 2022.
^ Cole, Ariane de Vogue, Devan (May 23, 2022). "Supreme Court makes it more difficult for prisoners to argue they had ineffective counsel | CNN Politics". CNN. Retrieved May 26, 2022.{{cite web}}: CS1 maint: multiple names: authors list (link)
^ Mangan, Dan (May 23, 2022). "Supreme Court makes it tougher for inmates to win release from prison due to bad lawyering claims". CNBC. Retrieved May 26, 2022.
^ "Supreme Court Decision Heavily Diminishes Ineffective Counsel Defense". The Seattle Medium. May 24, 2022. Retrieved May 26, 2022.

External links

Text of Shinn v. Ramirez, 596 U.S. ___ (2022) is available from: Justia Oyez (oral argument audio) Supreme Court (slip opinion)

[1] Totenburg, Nina (May 23, 2022). "Supreme Court hobbles challenges by inmates based on poor legal representation". NPR.

[2] Howe, Amy (May 17, 2021). "Court dismisses abortion "gag rule" cases, adds arbitration and habeas cases to docket". SCOTUSblog. Retrieved December 4, 2021.

[:0-3] "Conservative majority hollows out precedent on ineffective-counsel claims in federal court". SCOTUSblog. May 23, 2022. Retrieved May 26, 2022.

[4] Cole, Ariane de Vogue, Devan (May 23, 2022). "Supreme Court makes it more difficult for prisoners to argue they had ineffective counsel | CNN Politics". CNN. Retrieved May 26, 2022.{{cite web}}: CS1 maint: multiple names: authors list (link)

[5] Mangan, Dan (May 23, 2022). "Supreme Court makes it tougher for inmates to win release from prison due to bad lawyering claims". CNBC. Retrieved May 26, 2022.

[6] "Supreme Court Decision Heavily Diminishes Ineffective Counsel Defense". The Seattle Medium. May 24, 2022. Retrieved May 26, 2022.

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@@ Line 1: / Line 1: @@
-{{Use mdy dates|date=April 2021}}{{Italic title}}
+{{Use mdy dates|date=April 2021}}
 {{Infobox SCOTUS case
   |Litigants=Shinn v. Ramirez
@@ Line 8: / Line 8: @@
   |FullName=David Shinn, Director, Arizona Department of Corrections, Rehabilitation and Reentry, et al. v. David Martinez Ramirez and Barry Lee Jones
   |USVol=596
-  |USPage=___
+  |USPage=366
   |ParallelCitations=
   |Docket=20-1009
@@ Line 22: / Line 22: @@
 }}
-'''''Shinn v. Ramirez''''', 596 U.S. ___ (2022), was a case decided by the [[Supreme Court of the United States|United States Supreme Court]] related to the [[Antiterrorism and Effective Death Penalty Act of 1996]]. The court held that new evidence that was not in the state court's records, based on [[Ineffective assistance of counsel|ineffective assistance]] of post-conviction council, could not be used in an appeal to a federal court.
+'''''Shinn v. Ramirez''''', 596 U.S. 366 (2022), was a case decided by the [[Supreme Court of the United States|United States Supreme Court]] related to the [[Antiterrorism and Effective Death Penalty Act of 1996]]. The court held that new evidence that was not in the state court's records, based on [[Ineffective assistance of counsel|ineffective assistance]] of post-conviction counsel, could not be used in an appeal to a federal court.
 == Background ==
-David Ramirez and Barry Jones were convicted of murders in Arizona and sentenced to death in 1989 and 1994, respectively. Ramirez appealed to federal court where his federal public defenders uncovered evidence of intellectual disability and extensive childhood abuse that hadn't been presented at his initial trial. His new lawyers argued that his initial public defender's failure to present evidence that may have been mitigating constituted ineffective counsel.<ref>{{cite news |last=Totenburg|first=Nina|date=23 May 2022|title=Supreme Court hobbles challenges by inmates based on poor legal representation|url=https://www.capeandislands.org/2022-05-23/supreme-court-hobbles-challenges-by-inmates-based-on-poor-legal-representation|work=[[NPR]]|location= |access-date=}}</ref>
+David Ramirez and Barry Jones were convicted of murders in Arizona and sentenced to death in 1989 and 1994, respectively. Ramirez appealed to federal court where his federal public defenders uncovered evidence of intellectual disability and extensive childhood abuse that hadn't been presented at his initial trial. Jones also appealed to federal court, where federal investigators found evidence suggesting he was innocent. In both cases, the new lawyers argued that the failure of the initial public defenders to present evidence that could have been mitigating constituted ineffective counsel.<ref>{{cite news |last=Totenburg|first=Nina|date=23 May 2022|title=Supreme Court hobbles challenges by inmates based on poor legal representation|url=https://www.capeandislands.org/2022-05-23/supreme-court-hobbles-challenges-by-inmates-based-on-poor-legal-representation|work=[[NPR]]|location= |access-date=}}</ref>
-In ''[[Martinez v. Ryan]]'' (2018), the Supreme Court held that prisoners may use post-conviction counsel's ineffectiveness as a reason to overcome procedural default. The [[United States Court of Appeals for the Ninth Circuit]] applied ''Martinez'' to rule for Ramirez and Jones on their habeas corpus petitions. The Court denied rehearing ''en banc'' over the dissent of Judge [[Daniel P. Collins]] and seven other judges. Arizona filed a petition for a writ of certiorari.<ref>{{Cite web|last=Howe|first=Amy|date=May 17, 2021|title=Court dismisses abortion “gag rule” cases, adds arbitration and habeas cases to docket|url=https://www.scotusblog.com/2021/05/court-dismisses-abortion-gag-rule-cases-adds-arbitration-and-habeas-cases-to-docket/|access-date=December 4, 2021|website=[[SCOTUSblog]]}}</ref>
+In ''[[Martinez v. Ryan]]'' (2012), the Supreme Court held that prisoners may use post-conviction counsel's ineffectiveness as a reason to overcome procedural default. The [[United States Court of Appeals for the Ninth Circuit]] applied ''Martinez'' to rule for Ramirez and Jones on their habeas corpus petitions. The Court denied rehearing ''en banc'' over the dissent of Judge [[Daniel P. Collins]] and seven other judges. Arizona filed a petition for a writ of certiorari.<ref>{{Cite web|last=Howe|first=Amy|date=May 17, 2021|title=Court dismisses abortion "gag rule" cases, adds arbitration and habeas cases to docket|url=https://www.scotusblog.com/2021/05/court-dismisses-abortion-gag-rule-cases-adds-arbitration-and-habeas-cases-to-docket/|access-date=December 4, 2021|website=[[SCOTUSblog]]}}</ref>
 == Supreme Court ==
+''[[Certiorari]]'' was granted in the case on May 17, 2021. On May 23, 2022, the Supreme Court reversed the [[Ninth Circuit]] in a 6–3 opinion.
-Certiorari was granted in the case on May 17, 2021. On May 23, 2022, the Supreme Court reversed the Ninth Circuit in a 6–3 opinion.
 === Majority opinion ===
-The majority opinion was authored by [[Clarence Thomas|Thomas]], and joined by [[John Roberts|Roberts]], [[Samuel Alito|Alito]], [[Neil Gorsuch|Gorsuch]], [[Brett Kavanaugh|Kavanaugh]], and [[Amy Coney Barrett|Barret]], the court's six [[Conservatism|conservative]] justices.<ref name=":0">{{Cite web |date=2022-05-23 |title=Conservative majority hollows out precedent on ineffective-counsel claims in federal court |url=https://www.scotusblog.com/2022/05/conservative-majority-hollows-out-precedent-on-ineffective-counsel-claims-in-federal-court/ |access-date=2022-05-26 |website=SCOTUSblog |language=en-US}}</ref> Thomas stated that allowing claims like the one is the case would cause delays in the future, and noted the brutality of the crimes that were committed.<ref>{{Cite web |last=Cole |first=Ariane de Vogue,Devan |date=2022-05-23 |title=Supreme Court makes it more difficult for prisoners to argue they had ineffective counsel {{!}} CNN Politics |url=https://www.cnn.com/2022/05/23/politics/supreme-court-prisoners-federal-court-evidence/index.html |access-date=2022-05-26 |website=CNN |language=en}}</ref> He also cited a dissent written by the late Justice [[Antonin Scalia|Scalia]] in ''Martinez'', and another dissenting opinion written by Roberts in ''Trevino v. Thaler'' (2013), a case that applied ''Martinez''.<ref name=":0" />
+The majority opinion was authored by [[Clarence Thomas]], and joined by [[John Roberts]], [[Samuel Alito]], [[Neil Gorsuch]], [[Brett Kavanaugh]], and [[Amy Coney Barrett]], the court's six conservative justices.<ref name=":0">{{Cite web |date=2022-05-23 |title=Conservative majority hollows out precedent on ineffective-counsel claims in federal court |url=https://www.scotusblog.com/2022/05/conservative-majority-hollows-out-precedent-on-ineffective-counsel-claims-in-federal-court/ |access-date=2022-05-26 |website=SCOTUSblog |language=en-US}}</ref> Thomas stated that allowing claims, like the ones in this case, would cause delays in the future, and cited the brutality of the crimes that were committed.<ref>{{Cite web |last=Cole |first=Ariane de Vogue, Devan |date=2022-05-23 |title=Supreme Court makes it more difficult for prisoners to argue they had ineffective counsel {{!}} CNN Politics |url=https://www.cnn.com/2022/05/23/politics/supreme-court-prisoners-federal-court-evidence/index.html |access-date=2022-05-26 |website=CNN |language=en}}</ref> He also cited a dissent written by the late Justice [[Antonin Scalia]] in ''Martinez'', and another dissenting opinion written by Roberts in ''Trevino v. Thaler'' (2013), a case that applied ''Martinez''.<ref name=":0" />
 === Dissenting opinion ===
-The dissenting opinion was authored by [[Sonia Sotomayor|Sotomayor]], and joined by [[Elena Kagan|Kagan]] and [[Stephen Breyer|Breyer]], the court's three [[Liberalism|liberal]] justices.<ref>{{Cite web |last=Mangan |first=Dan |date=2022-05-23 |title=Supreme Court makes it tougher for inmates to win release from prison due to bad lawyering claims |url=https://www.cnbc.com/2022/05/23/supreme-court-decision-makes-it-tougher-for-inmates-to-win-release-from-prison.html |access-date=2022-05-26 |website=CNBC |language=en}}</ref> She described the decision as "perverse" and "illogical".<ref>{{Cite web |date=2022-05-24 |title=Supreme Court Decision Heavily Diminishes Ineffective Counsel Defense |url=https://seattlemedium.com/supreme-court-decision-heavily-diminishes-ineffective-counsel-defense/ |access-date=2022-05-26 |website=The Seattle Medium |language=en-US}}</ref> Sotomayor also attacked the majority opinion's citations of previous dissenting opinions to back up its reasoning. She also hinted that doing so could make the Supreme Court's decision making process appear [[Legitimacy (political)|illegitimate]].<ref name=":0" />
+The dissenting opinion was authored by [[Sonia Sotomayor]], and joined by [[Elena Kagan]] and [[Stephen Breyer]], the court's three liberal justices.<ref>{{Cite web |last=Mangan |first=Dan |date=2022-05-23 |title=Supreme Court makes it tougher for inmates to win release from prison due to bad lawyering claims |url=https://www.cnbc.com/2022/05/23/supreme-court-decision-makes-it-tougher-for-inmates-to-win-release-from-prison.html |access-date=2022-05-26 |website=CNBC |language=en}}</ref> She described the decision as "perverse" and "illogical".<ref>{{Cite web |date=2022-05-24 |title=Supreme Court Decision Heavily Diminishes Ineffective Counsel Defense |url=https://seattlemedium.com/supreme-court-decision-heavily-diminishes-ineffective-counsel-defense/ |access-date=2022-05-26 |website=The Seattle Medium |language=en-US}}</ref> Sotomayor also attacked the majority opinion's citations of previous dissenting opinions to back up its reasoning. She also hinted that doing so could make the Supreme Court's decision making process appear [[Legitimacy (political)|illegitimate]].<ref name=":0" />
 == References ==
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  | other_url1 = https://www.supremecourt.gov/opinions/21pdf/20-1009_19m2.pdf
  }}
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-[[Category:Antiterrorism and Effective Death Penalty Act case law]]
 [[Category:United States Supreme Court cases]]
 [[Category:United States Supreme Court cases of the Roberts Court]]
+[[Category:Antiterrorism and Effective Death Penalty Act case law]]