Maples v. Thomas

Maples v. Thomas

Argued October 4, 2011
Decided January 18, 2012
Full case name Cory S. Maples v. Kim T. Thomas, Commissioner, Alabama Department of Corrections
Docket nos. 10-63
Citations

565 U.S. ___ (more)

Prior history Conviction affirmed sub nom. Maples v. State, 758 So.2d 1 (Ala. Crim. App. 1999); Ex parte Maples, 758 So.2d 81 (Ala. 1999); denial of petition for postconviction relief affirmer, Ex parte Maples, 885 So.2d 845 (Ala. Crim. App. 2004); petition for habeas corpus relief denied sub nom. Maples v. Campbell, No. 5:03-CV-2399-SLB-PWG (N.D. Ala. September 29, 2006); affirmed sub nom. Maples v. Allen, 586 F.3d 879 (11th Cir. 2009)
Holding
Maples has shown the requisite “cause” to excuse his procedural default due to the abandonment of his attorneys during a critical stage of his appeals.
Court membership
Chief Justice
John G. Roberts
Case opinions
Majority Ginsburg, joined by Roberts, Kennedy, Breyer, Alito, Sotomayor, Kagan
Concurrence Alito
Dissent Scalia, joined by Thomas

Maples v. Thomas, 565 U.S. ___ (2012), is a United States Supreme Court ruling in which the Court ruled 7–2 that Cory R. Maples, who had been convicted of murdering two people and faced a possible death sentence, should get another opportunity in court because his lawyers at Sullivan & Cromwell had abandoned him.[1]

Justices Antonin Scalia and Clarence Thomas dissented from the Court's holding, arguing that the procedural default shouldn't be excused.

Facts

In 1997 Cory Maples was convicted of murder and received the death sentence in Alabama. Alabama does not provide death row inmates with lawyers to appeal their convictions and sentences so they must rely on pro bono lawyers to represent them. Two lawyers from the New York law firm Sullivan and Cromwell agreed to represent Maples free of charge. Those lawyers later quit the law firm and when the Alabama court sent copies of a ruling in Maples' case to the firm's mail room, the law firm returned the copies unopened. The law firm never notified the court or the mail room that new lawyers had taken over the case. Because this information was never received the deadline for appeal was missed. When Maples learned of the missed deadline, he had his step-mother contact the law firm. The lawyers now handling the case ask for permission to still appeal despite missing the original deadline, but that request was denied.[2]

Background

The sixth amendment gives defendants the right to counsel. The Supreme Court ruled in 1976 (citing Brewer v. Williams, 430 U.S. 387 at 398) that a defendant deserves the right to an attorney “at or after the time that judicial proceedings have been initiated against him, whether by formal charge, preliminary hearing, indictment, information, or arraignment”.[3]

Decision

On January 18, 2012, the Supreme Court decided in favor of Cory Maples because of the special circumstances of his case. The unannounced and unauthorized abandonment of Maples' case by his lawyers proved significant enough to excuse the defendant from having failed to file an appeal in advance of the deadline.

Opinion of the Supreme Court

Justice Ruth Bader Ginsburg delivered the opinion of the Court. In it, she reversed the findings of the circuit court and discussed Alabama’s practices in regard to post-conviction representation. The court held that because Maples' non-compliance with State rules were set in motion by external circumstance outside of his knowledge or control he could not be held responsible. Attorney negligence doesn't normally excuse the client from responsibility because the attorney is acting as an agent to the client and the client is therefore responsible and able to manage the actions of his attorney. In Maples' case, however, he was abandoned, without notice, by his attorneys and this effectively severed the relationship.

Justice Samuel Alito concurred with Ginsburg is his opinion while Justice Antonin Scalia dissented in his own. Scalia agreed that abandonment was a legitimate reason to sever the relationship but that Maples' had not been abandoned. He was, without interruption, represented by Sullivan and Cromwell and John Butler, an Alabama attorney. [4]

References

  1. ↑ "Justices Rule for Inmate After Mailroom Mix-Up". New York Times. January 18, 2012.
  2. ↑ http://www.oyez.org/cases/2010-2019/2011/2011_10_63
  3. ↑ http://www.gpo.gov/fdsys/pkg/GPO-CONAN-2002/pdf/GPO-CONAN-2002-9-7.pdf
  4. ↑ http://www.oyez.org/cases/2010-2019/2011/2011_10_63#mla

Further reading

External links

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