Maples v. Thomas

Background

Cory Maples was an Alabama death-row prisoner who sought state postconviction relief after his 1997 capital conviction. Two young New York lawyers from a large firm agreed to represent him pro bono and associated a local Alabama attorney who said he would play only a formal role. The two New York lawyers left the firm for other jobs, did not tell Maples, and did not seek the court’s permission to withdraw. Notices of the trial court’s denial were mailed to the firm, returned unopened, and no appeal was filed before the 42-day deadline expired.

Reasoning

The Court addressed whether those facts show enough "cause" to excuse Maples’ missed appeal deadline and allow federal review. Relying on basic agency principles, the Court distinguished ordinary attorney mistakes from true abandonment: when lawyers abandon a client without notice, they cease to be that client’s agents and their failures cannot fairly be charged to the client. Applying that rule, the Court concluded Maples’ lawyers had abandoned him, excused the procedural default, reversed the Eleventh Circuit, and sent the case back for further proceedings to decide prejudice.

Real world impact

This decision means courts may excuse missed state deadlines when a client was effectively left without authorized counsel and had no reason to protect himself. It will most directly affect defendants who rely on out-of-state or volunteer counsel and prompts courts to examine whether listed lawyers actually represented a client. The ruling decides only that Maples showed cause; whether his claims have merit or caused prejudice remains for the lower courts to decide.

Dissents or concurrances

Justice Alito joined the opinion, calling the events a unique perfect storm leading to abandonment. Justice Scalia (joined by Justice Thomas) dissented, arguing the firm and local counsel remained responsible and that this decision undermines rules holding clients accountable for their lawyers’ errors.