Murray v. Giarratano

1989-06-23

Headline: Death-row inmates’ claim for free lawyers in state postconviction cases is rejected; Court limits access-to-courts rule and lets states decide whether to provide appointed counsel, affecting prisoners seeking collateral relief.

Holding:

Real World Impact:

No federal constitutional right to appointed counsel in state postconviction proceedings for death row inmates.
States may still provide counsel under their own laws or programs; Court leaves decisions to states.
Lower courts can require better law-library access or timing fixes without creating a nationwide counsel rule.

Topics: death penalty, right to counsel, postconviction review, access to courts

Summary

Background

Virginia death row inmates sued state officials after a federal district court certified a class and found Virginia's procedures left condemned prisoners without meaningful access to state postconviction review. The District Court ordered appointment of counsel upon request, and the Fourth Circuit en banc affirmed that relief. The inmates argued they needed appointed lawyers to prepare and pursue habeas and other collateral claims prior to execution.

Reasoning

The Supreme Court majority reversed, applying this Court's earlier decision in Pennsylvania v. Finley and limiting the reach of Bounds v. Smith. The majority explained that state postconviction proceedings are not part of the criminal trial process and that the Constitution does not automatically require states to provide appointed lawyers for those proceedings, even in capital cases. The Court said existing Eighth and Fourteenth Amendment protections at trial and appeal are sufficient, and left resource allocation and broader reforms to state legislatures and Congress.

Real world impact

The ruling means there is no federal constitutional rule forcing states to appoint counsel before a condemned prisoner files postconviction petitions. States retain discretion to create programs, appoint counsel under state law, or improve law-library access. The District Court was told it can still require practical remedies like better access to legal materials if Virginia's practices deny meaningful access.

Dissents or concurrances

Justice Stevens, joined by three Justices, dissented, arguing that the unique finality and complexity of death cases make appointed counsel necessary to ensure fairness; he urged that Virginia's record showed condemned inmates lacked adequate assistance.