On January 18, the U.S. Supreme Court (7-2) ordered a new hearing in federal court for Cory Maples, an Alabama death row inmate whose state and federal appeals had been rejected by lower courts because his lawyers quit and missed a critical filing deadline. Copies of an Alabama court ruling in Maples’s case were sent to a volunteer New York law firm handling his appeals but were unopened by the mailroom and returned to the state court because the attorneys representing Maples had left the firm. Justice Samuel Alito, concurring in the Court’s opinion, wrote that the circumstances surrounding this case created a “veritable perfect storm of misfortune.” On behalf of the majority, Justice Ruth Ginsburg wrote, “Maples was disarmed by extraordinary circumstances quite beyond his control. He has shown ample cause, we hold, to excuse the procedural default into which he was trapped when counsel of record abandoned him without a word of warning.”

Because Maples missed the filing deadline to appeal in state court, his federal habeas corpus petition was also defaulted, thereby ending his appeals and opening the door to his execution. Federal courts allow an exception for such default if the defendant can show there was good cause for the default, and that not being able to appeal prejudiced his case. Generally, a mistake by one’s appellate attorney during this phase of the appeals is not considered good cause. However, in this instance the Supreme Court held that the appellate lawyers at the New York firm had done more than make a mistake—they completely abandoned Maples at a critical time in the process. Since Maples had no effective representation at a time in which he was relying on his lawyers to file his appeal, there was good cause for the default. Justice Ginsburg wrote,”In these circumstances, no just system would lay the default at Maples’ death-cell door.” The Supreme Court sent the case back to federal court to determine if his case was hurt by not being able to appeal his conviction or sentencing.

One of the issues that Maples was trying to appeal was the quality of the representation he received at trial. Justice Ginsburg described the trial attorneys appointed by Alabama as “minimally paid and with scant experience in capital cases.”

Justices Antonin Scalia and Clarence Thomas dissented, maintaining that Maples did have some form of representation from the N.Y. firm and from a local Alabama attorney retained solely for procedural reasons.

(R. Barnes, “Supreme Court: Alabama death-row inmate Cory Maples should get new hearing,” Washington Post, January 18, 2012). Read full U.S. Supreme Court opinion (Maples v. Thomas, No. 10-63). See Representation and U.S. Supreme Court.

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