Rodney v. Filson

The 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. View "Rodney v. Filson" on Justia Law