Cory Maples Should Not Face Death Penalty Due To Mailroom Mix-Up, Supreme Court Rules
An Alabama death row inmate stymied by a law firm's egregious mail room mix-up will have the opportunity to appeal his death sentence, the Supreme Court ruled on Wednesday morning.
In 2001, Cory Maples thought he had won the lottery when he obtained the help of two attorneys at Sullivan & Cromwell, a prestigious New York law firm, to convince an Alabama trial court that his death sentence four years earlier was due to unconstitutionally bad lawyering. That luck, it turned out, was short-lived.
First, his two lawyers left the firm before the trial court decided if it would give Maples the postconviction relief he sought. Then, the court denied Maples that relief and sent notice to the New York law firm, unaware the attorneys no longer worked there. The firm, in turn, returned the notice unopened to the trial court clerk, who then proceeded to take no action.
Only after the state sent Maples a letter in prison that his time to appeal had expired did his mother call Sullivan & Cromwell to ask about her son's case. Egg on its face, the firm pleaded with the trial court to restart the appeal period. But by then, the damage had been done: All state and federal courts refused to excuse Maples for his attorneys' failure to file a timely appeal, communication breakdowns and mailroom blunders notwithstanding.
Those decisions relied on settled precedents that clients bear risk of their lawyers' negligence. Missing a filing deadline is a textbook example of such negligence that courts often refuse to excuse.
But the Supreme Court, siding with Maples in a 7-2 vote, found that the facts surrounding Maples' case amounted to more than simple attorney negligence. Maples, wrote Justice Ruth Bader Ginsburg on behalf of the Court, had been effectively abandoned not only by the two New York lawyers, but also by the Alabama lawyer, John Butler, whom the lawyers had associated with in order to practice in Alabama. Butler, upon signing onto the case, told his colleagues that he would not make any actual contribution to the case, contrary to Alabama's requirement that local counsel be more than simple facilitators for out-of-state representation.
"That the minimal participation he undertook was inconsistent with Alabama law," Ginsburg wrote, "underscores the absurdity of holding Maples barred because Butler signed on as local counsel."
"Abandoned by counsel, Maples was left unrepresented at a critical time for his state postconviction petition, and he lacked a clue of any need to protect himself," Ginsburg continued. "In these circumstances, no just system would lay" the blame for Maples' missing the deadline to appeal at his "death-cell door."
The Court rarely takes cases that offer no opportunity to issue a broadly applicable rule of law, even if those cases present clear cases of injustice against specific individuals. But Maples' case presented such an extraordinary set of facts -- described in a short concurrence by Justice Samuel Alito as "a veritable perfect storm of misfortune, a most unlikely combination of events" -- that the Court intervened on Maples' behalf.
Responding to the decision, John Payton, the director-counsel of the NAACP Legal Defense & Educational Fund, told HuffPost that the ruling, despite its narrow application to Maples alone, "focuses attention on the larger issue that death should not be the consequence of someone having an inadequate lawyer."
This was precisely the point that seemed to motivate Justice Antonin Scalia, joined by Justice Clarence Thomas, in his dissent. Refusing to find that Maples had been abandoned by his lawyers, which also included the New York attorneys' superiors at the law firm, Scalia wrote that the majority's reasoning "invites future evisceration of the principle that defendants are responsible for the mistakes of their attorneys."
But there are mistakes, and then there are mistakes, emphasized Payton. "There are a lot of other eye-popping cases out there that are just heartbreaking for what went wrong," he said.