Where, under Arizona law, ineffective-assistance-of-trial-counsel claims had to be raised in an initial-review collateral proceeding, procedural default did not bar federal district court from hearing those claims where, in initial-review collateral proceeding, there was no counsel or counsel in that proceeding was ineffective. (Kennedy, J.)
Martinez v. Ryan
U.S. Sup. Ct.
March 20, 2012
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