SCOTUS issues decision in Martinez Ramirez

The Supreme Court issued its decision in Shinn v. Martinez Ramirez, 596 U.S. ___, 2022 WL 1611786 (May 23, 2022), holding that the equitable rule announced in Martinez v. Ryan providing that ineffective assistance of postconviction counsel can provide “cause” to forgive the procedural default of a claim of ineffective assistance by trial counsel does not permit a federal court to dispense with 28 U.S.C. § 2254(e)(2)’s narrow limits on federal evidentiary hearings even where a prisoner’s state postconviction counsel was at fault for failing to develop the state-court record on the ineffective assistance of trial counsel claim.