Term: 2011
Docket: 10-63
Cory R. Maples, Petitioner v. Kim T. Thomas, Commissioner, Alabama Department Of Corrections
- Pro
10-63 MAPLES V. THOMAS, INTERIM COMMISSIONER, AL D.O.C. DECISION BELOW: 586 F.3d 879 LIMITED TO QUESTION 2 PRESENTED BY THE PETITION. CERT. GRANTED 3/21/2011 QUESTION PRESENTED: In this capital case, the divided Eleventh Circuit held that Alabama may execute a state inmate without any federal court review of the merits of serious constitutional claims because of a missed filing deadline that indisputably occurred through no fault of petitioner and after the State failed to take any action when court orders mailed to petitioner's lead attorneys of record were returned to a court clerk unopened with "Return to Sender - Left Firm" written on an envelope. The questions presented are as follows: 1. Whether the Eleventh Circuit properly held - in conflict with the decisions of this Court and other circuits - that the purported state procedural default rule is "adequate" as a matter of federal law to bar federal habeas review of serious constitutional claims, where the court of appeals disregarded state case law allowing untimely appeals in analogous circumstances, reconstructed state law based on distinctions not drawn by the state courts themselves, and relied on cases decided after the asserted default. 2. Whether the Eleventh Circuit properly held - in conflict with the decisions of this Court and other courts - that there was no "cause" to excuse any procedural default where petitioner was blameless for the default, the State's own conduct contributed to the default, and petitioner's attorneys of record were no longer functioning as his agents at the time of any default. LOWER COURT CASE NUMBER: 07-15187
In the 2011 case of Cory R. Maples v. Kim T. Thomas, Commissioner, Alabama Department of Corrections, the U.S Supreme Court ruled in favor of Maples who was convicted for murder and sentenced to death by an Alabama court. The crux of this case revolved around a missed deadline for appeal due to his lawyers leaving their law firm without notifying him or properly transferring his representation; as such he had no legal counsel when crucial documents were mailed to him regarding his right to appeal which subsequently got returned unopened. When Maples realized what happened, he petitioned that he should not be penalized because it was not his fault but rather negligence on part of his attorneys and the lower courts disagreed stating rules are rules regardless if they seem harsh under certain circumstances like these where there is attorney abandonment involved . However, upon reaching the Supreme Court level , Justice Ruth Bader Ginsburg writing for majority (7-2) held that given these extraordinary circumstances involving gross negligence from licensed attorneys causing a client's default , principles underlying our constitutional system will hold such defaults excused hence allowing Maple another chance at appealing against his conviction.
In the dissenting opinion for Cory R. Maples v. Kim T. Thomas, Justice Scalia argued that the majority's decision was based on sympathy rather than legal principles and precedent. He contended that Maples' attorneys were not acting as agents of Sullivan & Cromwell when they left the firm without notifying him or ensuring his case would be handled properly, but instead acted in their individual capacities as volunteers who had taken on a pro bono client while at the firm. Therefore, he believed it was incorrect to hold Sullivan & Cromwell responsible for their actions after leaving its employ and wrong to excuse Maples' procedural default due to abandonment by counsel because there was no agency relationship between them at that time.
