Kyle James Moesch v. Texas

In Douglas v. California, 372 U.S. 353, 357 (1963), this Court held that prisoners are entitled to counsel on their as-of-right direct appeal because “where the merits of the one and only appeal an indigent has as of right are decided without benefit of counsel… an unconstitutional line has been drawn between rich and poor.” Six years ago, this Court recognized that collateral proceedings that provide the first occasion to raise a claim of ineffective assistance at trial are “in many ways the equivalent of a prisoner’s direct appeal as to the ineffective-assistance claim.” Martinez v. Ryan, 566 U.S. 1, 11–13 (2012). Is a prisoner who raises a claim of ineffective assistance of trial counsel in initial-review collateral proceedings thus entitled to the assistance of counsel?