Maples v. Thomas

Petitioner must show adequate "cause" to excuse a failure to timely file an appeal when the filing deadline lapses.

Petitioner was convicted of capital murder and sentenced to death for the shooting deaths of two men. After his conviction, Petitioner sought post conviction relief alleging that his trial counsel failed to render effective legal assistance as guaranteed by the Sixth Amendment. Two pro bono attorneys associated with a New York law firm served as Petitioner’s attorneys of record and drafted his petition to the state court. While the petition was pending, the attorneys left the law firm and secured new employment, which precluded them from continuing the representation. The attorneys did not inform Petitioner or the court of the inability to continue to serve as counsel. The state subsequently denied Petitioner’s post conviction petition and with no attorneys of record acting on Petitioner’s behalf the deadline to file an appeal lapsed. Petitioner filed a petition for writ of habeas corpus in federal court. The District Court, and, in turn, the Eleventh Circuit rejected the petition due to the failure to timely file an appeal.

The Supreme Court reversed the Eleventh Circuit, holding that Petitioner had shown ample “cause” to excuse his procedural default. Petitioner was left without legal representation at a critical time in his post conviction petition without knowledge of the attorney withdrawal. Since his attorneys failed to notify the court of their departure Petitioner was not entitled to personally receive notice of the denial of his petition and received none until after the time to file an appeal had expired. To deny Petitioner’s appeal based on a procedural fault that occurred through no fault of his own would contravene principles of fundamental fairness.