Donnie Morgan, Warden v. Vincent D. White, Jr.

The procedural-default doctrine bars federal courts from awarding habeas relief for claims “that a state court refused to hear based on an adequate and independent state procedural ground.” Davila v. Davis, 137 S. Ct. 2058, 2062 (2017). Federal courts may excuse a procedural default only if the petitioner “can establish ‘cause’ to excuse the procedural default and demonstrate that he suffered actual prejudice from the alleged error.” Id. (emphasis added). In Martinez v. Ryan, 566 U.S. 1 (2012), the Supreme Court held that petitioners can, in narrow circumstances, establish “cause” by showing that the absence or ineffective performance of state-postconviction counsel caused them to procedurally default an ineffectiveassistance-of-trial-counsel claim that had “some merit.” Id. at 14. This case presents the following question: If a petitioner defaults an ineffective-assistance-of-trialcounsel claim with “some merit,” does Martinez v. Ryan allow a federal court to excuse the procedural default without requiring any further showing of prejudice?