In Davila v. Davis, No. 16-6219, the Supreme Court held that ineffective assistance of counsel in state post-conviction proceedings does not qualify as cause to excuse the procedural default of ineffective-assistance-of-appellate-counsel claims. The Court refused to extend the exceptions (to the general rule that because a prisoner does not have a constitutional right to counsel in state postconviction proceedings, ineffective assistance in those proceedings does not qualify as cause to excuse a procedural default) found in Martinez v. Ryan, 566 U. S. 1 (2012), and Trevino v. Thaler, 569 U. S. 413 (2013), to defaulted ineffective assistance of appellate counsel claims.
Opinion by Justice Thomas. Justice Breyer dissented, joined by Justices Ginsburg, Sotomayor, and Kagan.
For the opinion, click here.