Shinn v. Ramirez

Does application of the equitable rule this Court announced in Martinez v. Ryan render 28 U.S.C. § 2254(e)(2) inapplicable to a federal court’s merits review of a claim for habeas relief?

Petitioners are Arizona state corrections officials and Respondents are incarcerated felons convicted of murder. Respondents sought habeas corpus review, which the district court denied for procedural reasons. Respondents appealed to the 9th Circuit, and in light of Martinez v. Ryan, the lower court reversed in part which gave Respondents the opportunity to have hearings on their claims. Petitioners argued that, pursuant to Martinez, Respondents do have the right to be heard on the merits, notwithstanding their habeas procedural defects. However, Petitioners claim that a merit review is still subject to statutory limitations, specifically under 28 U.S.C. § 2254(e)(2). Petitioners reason that the congressional intent of § 2254(e)(2) is undermined by the 9th Circuit’s interpretation. Further, Petitioners argue that the statute precludes any evidence that was not developed in the state court record, in turn, the court’s review is significantly limited. Petitioners claim that a judge-made equitable remedy for a procedural defect cannot disregard statutory limitations on the merits of habeas claims. Finally, Petitioners argue that because Martinez never addressed the statute, it cannot be said to have overruled it.