Miles v. Martel

Under 28 U.S.C. § 2254(d), a federal court can remand a claim of a person in state custody for an evidentiary hearing for the purpose of reviewing that claim.

Tyrone Wayland Miles (Miles) alleged that, during the plea bargaining process, he received ineffective assistance of counsel. According to Miles, his counsel advised him not to take a plea offer of six years in prison without informing him that the crime he was charged with would be his “third strike” under California Law. Miles entered an open plea and received “a three strikes sentence of twenty-five years to life in prison.” Miles filed a petition for a writ of habeas corpus with the California Supreme Court. In the petition, he claimed that he received “ineffective assistance of counsel during plea bargaining and sentencing.” His petition was summarily denied without an evidentiary hearing. Miles then filed a federal petition of writ of habeas corpus, but the district court denied his petition. He appealed. The United States Supreme Court’s decision in Strickland v. Washington established the federal law governing ineffective assistance of counsel. The Ninth Circuit reasoned that the state court had not correctly applied Strickland to Miles’s alleged facts. After applying the United States Supreme Court’s recent interpretations of Strickland from its decisions in Lafler v. Cooper and Missouri v. Frye, the Ninth Circuit concluded that Miles’s alleged facts established a “prima facie case of ineffective assistance of counsel.” The Court determined that 28 U.S.C. § 2254(d) granted it the authority “to issue habeas corpus relief for persons in state custody,” which allowed the Court to remand Miles’s claim for an evidentiary hearing for the purpose of reviewing it. Thus, the Court held that Miles had established a prima facie case of ineffective assistance to counsel and that it could remand Miles’s claim for an evidentiary hearing. REVERSED and REMANDED.