Rodney v. Filson, No. 17-15438 (9th Cir. 2019)
Annotate this CaseThe Ninth Circuit vacated the district court's denial of petitioner's pro se 28 U.S.C. 2254 habeas corpus petition based on claims of ineffective assistance of counsel (IAC). The panel held that petitioner need only show that his IAC claims were substantial in order to excuse the procedural default of the claims under Martinez v. Ryan, 566 U.S. 1 (2012). Furthermore, because the district court failed to conduct a Martinez analysis, it did not make any findings on the issue. In this case, the panel could not conclude on the record that petitioner's IAC claims were meritless under the deficient performance prong of Strickland v. Washington, 466 U.S.C. 668 (1984). Therefore, the panel remanded for the district court to conduct an analysis of the substantiality of the IAC claims.
Court Description: Habeas Corpus The panel vacated the district court’s denial of Nevada state prisoner Kyle J. Rodney’s pro se 28 U.S.C. § 2254 habeas corpus petition and remanded for the district court to conduct an analysis of the substantiality of Rodney’s ineffective-assistance-of-counsel (IAC) claims pursuant to Martinez v. Ryan, 566 U.S. 1 (2012). Without allowing discovery, holding an evidentiary hearing, or engaging in a Martinez analysis, the district court found, in relevant part, that two of Rodney’s IAC claims were procedurally defaulted. The panel rejected Respondent’s argument that Rodney waived his argument that he can show cause and prejudice under Martinez to excuse his procedural default. The panel explained that because Rodney was not represented by counsel during his initial-review collateral proceeding, he need only show that his IAC claims are substantial in order to excuse the procedural default. The panel could not conclude on the present record that Rodney’s IAC claims are meritless with respect to the deficient-performance prong of Strickland v. Washington, 466 U.S. 668 (1984). As to whether the alleged deficient performance resulted in prejudice, the panel observed that the district-court record is limited, and that both parties refer
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