Shinn v. Ramirez | Case No. 20-1009 | Date Argued: 12/8/2021 | Date Decided: 5/23/2022

Question Presented: The Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. § 2254(e)(2), precludes a federal court from considering evidence outside the state-court record when reviewing the merits of a claim for habeas relief if a prisoner or his attorney has failed to diligently develop the claim's factual basis in state court, subject to only two statutory exceptions. In Martinez v. Ryan, 566 U.S. 1 (2012), this Court announced an equitable exception to the procedural default bar, holding that a prisoner may obtain federal habeas review of a defaulted claim of ineffective assistance of trial counsel if post-conviction counsel was ineffective in failing to raise it. The Ninth Circuit has held that Martinez also requires an exception to § 2254(e)(2)'s prohibition on expansion of the state-court record in federal court. Does Martinez justify a federal habeas court's disregard of § 2254(e)(2)'s clear prohibition on expanding the state-court record?

Holding: 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 the ineffective assistance of state postconviction counsel.

Result: Judgment REVERSED.

Voting Breakdown: 6-3. Justice Thomas delivered the opinion of the Court, in which Chief Justice Roberts and Justices Alito, Gorsuch, Kavanaugh and Barrett joined. Justice Sotomayor filed a dissenting opinion, in which Justices Breyer and Kagan joined.

Link to Opinion: Here.

Oral Advocates:

For Petitioner: Brunn W. Roysden, III, Solicitor General, Phoenix, Ariz. For Respondents: Robert M. Loeb, Washington, D.C.