Trevino v. Thaler

Background

Carlos Trevino, convicted of capital murder in a Texas state jury trial, received the death penalty after the sentencing jury found future dangerousness and insufficient mitigation. New counsel handled his direct appeal but did not raise an ineffective-trial-counsel claim about failures to investigate or present mitigation. Later, federal habeas counsel discovered evidence of serious mitigation (prenatal alcohol exposure, low birth weight, head injuries, abuse, substance exposure) and sought federal review after state courts declined relief as procedurally defaulted.

Reasoning

The Court asked whether Martinez v. Ryan, which allowed federal review when state systems force defendants to raise certain claims first in collateral proceedings, applies in Texas. Texas law does not explicitly force initial collateral review, but the Court found Texas procedures and practice (tight time limits, delayed transcripts, and strong judicial and bar guidance favoring collateral habeas) make it virtually impossible to develop such claims on direct appeal. For those reasons, the Court concluded Martinez’s narrow exception applies in Texas and vacated the Fifth Circuit’s judgment, sending the case back for further proceedings.

Real world impact

The decision means some Texas defendants whose trial lawyers failed to investigate mitigation may get federal courts to consider those claims despite prior state procedural defaults. The Court did not decide whether Trevino’s specific claim is substantial or whether his state habeas lawyer was ineffective; those factual and legal issues return to lower courts and Texas courts to resolve.

Dissents or concurrances

Chief Justice Roberts (joined by Justice Alito) dissented, warning the majority expands Martinez beyond its narrow limits and weakens state finality and federalism; Justices Scalia and Thomas also dissented in related terms.