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Shinn v. Ramirez

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Supreme Court of the United States
Shinn v. Ramirez
Term: 2021
Important Dates
Argued: December 8, 2021
Decided: May 23, 2022
Outcome
Reversed
Vote
6-3
Majority
Clarence Thomas • Chief Justice John G. Roberts • Samuel Alito • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Dissenting
Sonia Sotomayor • Stephen Breyer • Elena Kagan

Shinn v. Ramirez is a case that was decided by the Supreme Court of the United States on May 23, 2022, during the court's October 2021-2022 term. The case was argued before the Supreme Court of the United States on December 8, 2021.

The court reversed the decision of the U.S. Court of Appeals for the 9th Circuit in a 6-3 ruling, holding that a federal court may not conduct an evidentiary hearing or allow new evidence to be considered in a case based on ineffective postconviction counsel. Justice Clarence Thomas delivered the majority opinion of the court. Justice Sonia Sotomayor filed a dissenting opinion, joined by Justices Stephen Breyer and Elena Kagan.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: David Ramirez was convicted of premeditated first-degree murder and sentenced to death in an Arizona state court. On appeal, his post-conviction attorney failed to raise a claim of ineffective assistance of trial counsel that Ramirez would later seek to introduce in a federal court proceeding for habeas relief. The district court found that federal law precluded Ramirez from raising the claim in federal court because it was not first raised in the state court proceedings. On appeal, the United States Court of Appeals for the 9th Circuit reversed the district court on this point, holding that the Supreme Court’s ruling in Martinez v. Ryan allowed Ramirez to develop evidence on the ineffective assistance of counsel claim during his habeas proceeding.[2] Click here to learn more about the case's background.
  • The issue: The case concerned the scope of evidence a federal appellate court can consider when reviewing a petition for habeas relief.
  • The question presented: "Does application of the equitable rule this Court announced in Martinez v. Ryan render 28 U.S.C. § 2254(e)(2) inapplicable to a federal court’s merits review of a claim for habeas relief?"[3]
  • The outcome: The court reversed the decision of the U.S. Court of Appeals for the 9th Circuit in a 6-3 ruling, holding that a federal court may not conduct an evidentiary hearing or allow new evidence to be considered in a case based on ineffective postconviction counsel.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    • May 23, 2022: The U.S. Supreme Court reversed the U.S. Court of Appeals for the 9th Circuit's ruling.
    • December 8, 2021: The U.S. Supreme Court heard oral argument.
    • October 22, 2021: The U.S. Supreme Court removed the case from the argument calendar for rescheduling. The case was originally scheduled for argument on November 1, 2021.
    • May 17, 2021: The U.S. Supreme Court agreed to hear the case.
    • January 20, 2021: David Shinn, the petitioner, appealed to the U.S. Supreme Court.
    • August 24, 2020: The 9th Circuit denied Shinn's petition for rehearing en banc.
    • September 11, 2019: A three-judge panel of the 9th Circuit affirmed in part, reversed in part, and remanded the United States District Court for the District of Arizona's ruling.

    Background

    In 1990, David Ramirez was convicted on two counts of premeditated first-degree murder in Arizona and sentenced to death on both counts. On direct appeal, the Arizona Supreme Court upheld Ramirez's conviction and sentence. His subsequent petition for post-conviction relief in state court was also denied. At that time, his post-conviction attorney failed to raise a claim of ineffective assistance of trial counsel in the petition for relief.[2]

    In 1997, Ramirez filed a petition for habeas relief with the United States District Court for the District of Arizona. Ramirez sought to add the ineffective assistance of trial counsel claim to the petition, but the district court ultimately found the claim was procedurally defaulted on independent and adequate state grounds—i.e., it was barred from consideration under Arizona state law because the post-conviction counsel had failed to raise it in the initial petition for post-conviction relief—and therefore it could not be considered by a federal court in habeas proceedings.[2] The federal Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. § 2254(e)(2), prevents a federal court from considering evidence during a habeas hearing that was not part of the state-court record if the defendant or defendant's attorney did not establish the claim's factual basis in state court.[3] Ramirez appealed the district court's decision to the United States Court of Appeals for the 9th Circuit, and while the appeal was pending, the U.S. Supreme Court decided Martinez v. Ryan, which held that "a procedural default will not bar a federal habeas court from hearing a substantial claim of ineffective assistance at trial if, in the initial-review collateral proceeding, there was no counsel or counsel in that proceeding was ineffective."[4] Accordingly, the 9th Circuit remanded the case to the district court for further proceedings. After conducting additional fact-finding hearings, the district court again found that Ramirez's ineffective assistance of trial counsel claim was procedurally barred and Ramirez again appealed to the 9th Circuit. The 9th Circuit determined that Martinez did excuse Ramirez's procedural default, and the court reversed the district court's judgment as to the procedural default and remanded the case for an evidentiary hearing on the issue.[2]

    David Shinn, as the director of the Arizona Department of Corrections, Rehabilitation, and Reentry, appealed the 9th Circuit's ruling, asking the Supreme Court to rule on how the court's decision in Martinez v. Ryan affects AEDPA's mandate that a federal court considering a habeas petition cannot examine evidence outside of the state-court record.[3]

    Question presented

    The petitioner presented the following question to the court:[3]

    Question presented:
    “ Does application of the equitable rule this Court announced in Martinez v. Ryan render 28 U.S.C. § 2254(e)(2) inapplicable to a federal court’s merits review of a claim for habeas relief?[5] ”

    Oral argument

    On October 22, 2021, the U.S. Supreme Court removed the case from the argument calendar for rescheduling. The case was originally scheduled for argument on November 1, 2021. The court heard oral argument on December 8, 2021.

    Audio

    Audio of oral argument:[6]



    Transcript

    Transcript of oral argument:[7]

    Outcome

    In a 6-3 ruling, the court reversed the decision of the 9th Circuit, holding a federal court may not conduct an evidentiary hearing or allow new evidence to be considered in a case based on ineffective postconviction counsel.[1] Justice Thomas delivered the opinion of the court. Justice Sotomayor dissented, joined by Justices Breyer and Kagan.

    Opinion

    In the court's majority opinion, Justice Thomas wrote:[1]

    “

    The State maintains that 28 U. S. C. §2254(e)(2) does not permit a federal court to order evidentiary development simply because postconviction counsel is alleged to have negligently failed to develop the state-court record. ... As relevant here, both Congress and federal habeas courts have set out strict rules requiring prisoners to raise all of their federal claims in state court before seeking federal relief.

    We now hold that, under §2254(e)(2), a federal habeas court may not conduct an evidentiary hearing or otherwise consider evidence beyond the state-court record based on ineffective assistance of state postconviction counsel.[5]

    		”
    —Justice Clarence Thoams

    Dissenting opinion

    Justice Sotomayor filed a dissenting opinion, joined by Justices Breyer and Kagan.

    In her dissent, Justice Sotomayor wrote:[1]

    “

    The Sixth Amendment guarantees criminal defendants the right to the effective assistance of counsel at trial. This Court has recognized that right as “a bedrock principle” that constitutes the very “foundation for our adversary system” of criminal justice. Martinez v. Ryan, 566 U. S. 1, 12 (2012). Today, however, the Court hamstrings the federal courts’ authority to safeguard that right. The Court’s decision will leave many people who were convicted in violation of the Sixth Amendment to face incarceration or even execution without any meaningful chance to vindicate their right to counsel. [5]

    		”
    —Justice Sonia Sotomayor

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[8]

    The court agreed to hear 68 cases during its 2021-2022 term.[9] Four cases were dismissed and one case was removed from the argument calendar.[10]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 Supreme Court of the United States, Shinn v. Ramirez, decided May 23, 2022
    2. ↑ 2.0 2.1 2.2 2.3 United States Court of Appeals for the 9th Circuit, Ramirez v. Ryan, decided September 11, 2019
    3. ↑ 3.0 3.1 3.2 3.3 U.S. Supreme Court, "Shinn v. Ramirez: Petition for Writ of Certiorari," accessed May 17, 2021
    4. ↑ United States Supreme Court, Martinez v. Ryan, decided May 15, 2006
    5. ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued December 8, 2021
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued December 8, 2021
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    9. ↑ Consolidated cases are counted as one case for purposes of this number.
    10. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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