Coleman v. Thompson
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Later courts report that Supreme Court act rather than create new treatments: the Ohio Court of Appeals, Eighth District, in State v. Glover and the Tenth Circuit in Ellis v. Smith are representative recognizers. The other reviewed opinions applied Coleman's procedural-default, cause-and-prejudice, adequate-state-ground, comity, finality, and postconviction-counsel rules; described Coleman's own treatment of older precedent; applied or declined to extend Martinez; repeated history parentheticals; or concerned unrelated authorities and party arguments. Withdrawn and reversed panel decisions supplied no treatment.
12,053 later cases cite Coleman v. Thompson; 321 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Coleman v. Thompson?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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The Supreme Court qualified Coleman's rule that postconviction-counsel error cannot establish cause by recognizing a narrow exception for inadequate assistance in an initial-review collateral proceeding on a substantial trial-ineffectiveness claim.
Martinez v. Ryan · Supreme Court of the United States · filed
To protect prisoners with a potentially legitimate claim of ineffective assistance of trial counsel, it is necessary to modify the unqualified statement in Coleman that an attorney’s ignorance or inadvertence in a postconviction proceeding does not qualify as cause to excuse a procedural default. This opinion qualifies Coleman by recognizing a narrow exception: Inadequate assistance of counsel at initial-review collateral proceedings may establish cause for a prisoner’s procedural default of a claim of ineffective assistance at trial.
Read the full opinion on CourtListener →
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