Hartman v. Payne, No. 19-3639 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of the 28 U.S.C. 2254 petition for habeas relief as procedurally defaulted. In this case, petitioner's ineffective-assistance-of-counsel claim was first procedurally defaulted on appeal, not at the initial-review collateral proceeding, which makes the Martinez exception inapplicable to petitioner's case. Therefore, with no excuse for the procedural default, federal habeas review of the claim is barred.
Court Description: [Stras, Author, with Gruender and Benton, Circuit Judges] Prisoner case - Habeas. Hartman procedurally defaulted his ineffective-assistance-of-trial-counsel claim; the procedural default in the case occurred on appeal and not in the initial-review collateral proceeding; in these circumstances, with no cause to excuse the procedural default, the claim is barred.
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