Shinn v. Martinez Ramirez
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Shinn v. Martinez Ramirez and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Shinn v. Martinez Ramirez.
The Supreme Court decided that under 28 U.S.C. § 2254(e)(2), federal habeas courts cannot conduct evidentiary hearings or consider evidence beyond the state-court record based on ineffective assistance of state postconviction counsel. This decision reversed the Ninth Circuit's ruling, which had allowed new evidence to be considered in the cases of Ramirez and Jones. The Court emphasized the importance of respecting state procedural rules and the limited scope of federal habeas review.
Holding
The single most important “bottom line” of what the Court decided in Shinn v. Martinez Ramirez.
The Court held that under § 2254(e)(2), a federal habeas court may not conduct an evidentiary hearing or consider evidence beyond the state-court record based on ineffective assistance of state postconviction counsel.
Constitutional Concepts
These are the Constitution-related themes that appear in Shinn v. Martinez Ramirez. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Shinn v. Martinez Ramirez
The case involves procedural rules related to federal habeas corpus review and the requirement for prisoners to exhaust state remedies.
Syllabus excerpt (verbatim)The Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) requires state prisoners to 'exhaus[t] the remedies available in the courts of the State' before seeking federal habeas relief.
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Why Right to Counsel is relevant to Shinn v. Martinez Ramirez
The case discusses the ineffective assistance of counsel in postconviction proceedings and its impact on procedural default.
Syllabus excerpt (verbatim)Martinez v. Ryan, 566 U. S. 1, which held that ineffective assistance of postconviction counsel may be cited as cause for the procedural default of an ineffective-assistance-of-trial-counsel claim.
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Why State–Federal Power is relevant to Shinn v. Martinez Ramirez
The decision emphasizes respect for state sovereignty and the limited role of federal habeas review.
Syllabus excerpt (verbatim)To respect federal-state dual sovereignty, see Printz v. United States, 521 U. S. 898, 918, the availability of federal habeas relief is narrowly circumscribed.
Key Quotes
Short excerpts from the syllabus in Shinn v. Martinez Ramirez that support the summary and concepts above.
Under § 2254(e)(2), a federal habeas court may not conduct an evidentiary hearing or otherwise consider evidence beyond the state-court record.
Federal habeas review is not 'a substitute for ordinary error correction through appeal,' but is an 'extraordinary remedy.'
A prisoner 'bears the risk in federal habeas for all attorney errors made in the course of the representation.'
