Skip to content
Name: Johnson v. Lee
Case #: 15-789
Court: US Supreme Court
District USSup
Opinion Date: 05/31/2016

California's procedural bar requiring defendants to raise available claims on direct appeal instead of by habeas petition is adequate to preclude federal review. Lee and her boyfriend were convicted of two counts of first degree murder. In 1999, her claims on direct appeal were rejected. She sought federal review, raising mostly new claims that had not been raised on appeal. The district court stayed federal proceedings while Lee pursued a state habeas petition. The California Supreme Court denied relief, citing In re Dixon (1953) 41 Cal.2d 756. The district court then dismissed her petition as procedurally defaulted. The Ninth Circuit…

View Full Summary
Name: Trevino v. Thaler
Case #: 11-10189
Court: US Supreme Court
District USSup
Opinion Date: 05/28/2013
Subsequent History: 133 S.Ct. 1911; 185 L.Ed.2d 1044

The exception to the procedural default rule laid out in Martinez v. Ryan applies where a state's procedural rules effectively prevent a defendant from raising ineffective assistance of counsel (IAC) claims on direct appeal. Trevino was convicted of murder and sentenced to death by a Texas jury in 1997. His attorneys appointed for the direct appeal and state habeas proceedings did not raise IAC of trial counsel in failing to investigate and present mitigating evidence. After this IAC claim was raised for the first time in federal habeas proceedings, the state court held that Trevino procedurally defaulted the claim…

View Full Summary
Name: Hill v. Roe
Case #: 00-56480
Court: US Court of Appeals
District 9 Cir
Opinion Date: 02/05/2003
Subsequent History: Previous opn. at 298 F.3d 796 (amended here) & rehrg. denied

When the California Supreme Court denied Hill’s habeas petition, it issued a letter stating in full: "Petition for writ of habeas corpus is DENIED. (In re Waltreus (1965) 62 Cal.2d 218, 225; People v. Hill (1973) 9 Cal.3d 784, 786, 787.)" The federal district court held that the Supreme Court’s citation to Waltreus did not bar federal court review, but that its citation to Hill did because it’s reference to Hill implies a denial of the state habeas on an independent and adequate state procedural bar. Under the independent and adequate state grounds doctrine, federal courts are barred…

View Full Summary