Antoin Deneil Marshal v. Texas

Petitioner was convicted of capital murder and sentenced to life without parole. The State obtained a conviction based on the testimony of: (1) an eyewitness who claimed that, while he was on his apartment balcony at 2:30 a.m., he heard a gunshot and saw petitioner and another man exit the building across the parking lot in which the shooting occurred; and (2) a career criminal with a pending habitual offender charge who claimed that petitioner had confessed to him in the jail. Eleven years after petitioner’s conviction became final, he filed a habeas corpus application alleging that his trial counsel was ineffective and that the State both failed to disclose impeachment evidence and presented and failed to correct false testimony. After a ten-day evidentiary hearing, the trial court–– without addressing the merits––recommended that the application be dismissed based on the doctrine of laches because petitioner unreasonably delayed filing it, and the State would be unduly prejudiced at a retrial. The Texas Court of Criminal Appeals (TCCA) denied relief by adopting the trial court’s findings and conclusions and also denied reconsideration. The questions presented are: I. Whether the TCCA’s application of the equitable doctrine of laches constitutes an independent and adequate state law ground that bars review of petitioner’s substantial constitutional claims.