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Name: Maples v. Thomas
Case #: Oct-63
Court: US Supreme Court
District USSup
Opinion Date: 01/18/2012
Subsequent History: 132 S.Ct.912; 181 L.Ed.2d 807
Summary

Lawyers who abandoned their capital habeas client without notice to the court or to the client provided extraordinary cause to grant relief from default. Maples was convicted of capital murder and sentenced to death in 1997 in Alabama. Maples’ postconviction petition filed in the trial court raised ineffective assistance of trial counsel. He was represented by two pro bono counsel who were associated with a large New York-based law firm. A local Alabama lawyer served only to move for their admission pro hac vice and it was understood that he would only facilitate their appearance with no substantive involvement in the case. The associates left the big firm and did not advise Maples, local counsel, or the court of their unavailability. Maples did not have a right to personal notice since he was represented by counsel and he did not receive notice when his petition was denied. State deadlines for further review were missed. Efforts to obtain relief from the default were denied. Maples then filed a state prisoner petition in federal district court. That was dismissed because of his failure to follow the state procedural requirements and he had not shown sufficient “cause” to overcome default. The Eleventh Circuit affirmed the dismissal based on Coleman v. Thompson (1991) 501 U.S. 722, 751 [ineffective assistance of postconviction appellate counsel could not qualify as cause to excuse default]. Certiorari was granted to determine if there was “cause” to excuse the default. A client cannot be faulted for failing to act on his own behalf when he lacks reason to believe that his attorneys have abandoned him. Relief was granted with remand to consider the question of “prejudice.”