Davila v. Davis

Background

A man named Erick Davila opened fire at a birthday gathering, killing two people and wounding others. He was convicted of capital murder after a jury was given a transferred-intent instruction the defense opposed. His appellate lawyer did not challenge that instruction, and his later state postconviction lawyer also did not raise an ineffective-appellate-counsel claim. Davila then sought relief in federal court, arguing that Martinez and Trevino should let him overcome the state procedural bar because his state postconviction lawyer was ineffective.

Reasoning

The Court considered whether the narrow Martinez/Trevino rule that sometimes excuses missed trial-ineffectiveness claims should be extended to claims that an appellate lawyer was ineffective. The majority said no. It explained that Martinez was a limited, equitable exception tied to the special importance of protecting trial rights and situations where state law channels trial-ineffectiveness claims into postconviction proceedings. Extending that exception to appellate-ineffectiveness claims would upset the normal rule that federal courts generally cannot hear claims a state court refused to consider because of a procedural rule.

Real world impact

The decision means that most federal habeas courts will not consider defaulted claims that an appellate lawyer was ineffective just because state postconviction counsel failed to raise them. That preserves procedural bars, reduces new federal review of many state convictions, and emphasizes finality and federalism. This ruling affirms the lower courts’ denial of Davila’s federal petition and is not a ruling on the underlying trial errors.

Dissents or concurrances

Justice Breyer (joined by three Justices) dissented, arguing Martinez should apply to appellate-ineffectiveness claims too, because the right to effective appellate counsel is important and the proposed extension would be limited and manageable.