Shinn v. Martinez Ramirez

This case consolidated two Arizona death row appeals. David Martinez Ramirez and Barry Lee Jones were convicted of separate murders and sentenced to death. In federal habeas corpus proceedings, both sought to introduce new evidence not previously developed in state court, arguing their state post-conviction counsel had been constitutionally ineffective. The U.S. Court of Appeals for the Ninth Circuit allowed them to supplement the record. The Supreme Court reversed. In a 6-3 ruling authored by Justice Clarence Thomas, the Court held that under 28 U.S.C. §2254(e)(2), federal courts generally cannot conduct evidentiary hearings or consider new evidence beyond the state court record when the claim was not properly developed in state court, even if the failure was due to the ineffective assistance of state post-conviction counsel.

The U.S. Supreme Court reversed the Ninth Circuit. The 6-3 majority held that §2254(e)(2) does not contain an exception for the ineffective assistance of state post-conviction counsel. Since the prisoners did not diligently develop the factual record in state court, the federal courts are barred from holding evidentiary hearings or considering new evidence in habeas proceedings.

Whether a federal court may consider evidence outside the state-court record when a prisoner's state post-conviction counsel failed to develop the factual basis of the claim, given the limits imposed by the Antiterrorism and Effective Death Penalty Act (AEDPA) under 28 U.S.C. §2254(e)(2).

The decision significantly restricts death row inmates' access to federal habeas corpus relief. Critics argue it creates a perverse incentive for states to provide inadequate post-conviction counsel and closes a vital safeguard against wrongful convictions. Supporters contend it reinforces federalism principles and finality in state criminal judgments. The ruling is seen as a major procedural blow to the ability to present new evidence of innocence in federal court.