Case Citator › Coleman v. Thompson

Coleman v. Thompson

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
501 U.S. 722
Decided
Confirmed treatments
1
Flagged citations read
321 of 321
Citing cases (total)
12,053
Treatment dates
2012

Status

Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Coleman v. Thompson has been limited: all 321 flagged citations have been read, with the one confirmed treatment listed below. Martinez v. Ryan expressly qualified Coleman's postconviction-counsel rule with a narrow equitable exception for certain defaulted claims of ineffective assistance at trial.
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 Withdrawn and reversed panel decisions supplied no treatment.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

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

  • 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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