No. 20-1009October Term 2020Decided May 23, 2022
Shinn v. Martinez Ramirez
The justices are being asked to decide how much room federal courts have to consider new evidence when state postconviction mistakes blocked an ineffective-lawyer claim.
Case status
- Current stage
- Decided
- Latest event
- Decision released May 23, 2022
- What it's about
This case involved two Arizona death row prisoners who argued in federal habeas proceedings that their trial lawyers were ineffective, even though those claims had not been properly developed in state court. The Supreme Court considered whether a federal court may look at new evidence outside the state-court record when the procedural default is excused because the prisoner’s state postconviction lawyer was ineffective.
Question presented
Does application of the equitable rule this Court announced in Martinez v. Ryan render 28 U.S.C. § 2254(e)(2) inapplicable to a federal court's merits review of a claim for habeas relief?
- Case path
United States Court of Appeals for the Ninth Circuit / Decision released May 23, 2022
- Area
Criminal Procedure
Briefing
What it's about
The case asks whether a federal court may consider new evidence that was not developed in state court when a prisoner's state postconviction lawyer was ineffective. It arises from two Arizona death row prisoners who say their trial lawyers were ineffective and that later lawyering failures kept those claims from being fully presented.
Vote
The case is pending, and no oral argument is scheduled yet. The dispute is whether the Martinez v. Ryan rule can let federal courts review new evidence despite the limits in 28 U.S.C. § 2254(e)(2).
Impact
The answer could shape how hard it is for prisoners to get federal review of serious claims after mistakes in state postconviction proceedings. For example, a death row inmate with new evidence about poor trial representation may or may not get a federal judge to look at it.
What's next
Watch for the Court to schedule oral argument or make another move in the case. No decision window is available yet.
What is the main legal fight in Shinn v. Martinez Ramirez?
The fight is over whether federal judges may look at new evidence outside the state-court record. That issue comes up when a prisoner's state postconviction lawyer was ineffective.
Who could be most affected by this case?
Prisoners seeking federal habeas review after serious state-lawyering mistakes could be most affected. That includes inmates with severe sentences, such as death row prisoners.
What should readers watch for next in this case?
Readers should watch for oral argument to be scheduled or for another docket move. The Court has not provided a decision window yet.
Decision
What the Court decided
The justices are being asked to decide how much room federal courts have to consider new evidence when state postconviction mistakes blocked an ineffective-lawyer claim.
Impact
The answer could shape how hard it is for prisoners to get federal review of serious claims after mistakes in state postconviction proceedings. For example, a death row inmate with new evidence about poor trial representation may or may not get a federal judge to look at it.
Not official Court text.
Opinion documents
Timing
Decided May 23, 2022
The Court released its decision on May 23, 2022 without hearing oral argument.
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Jul 2, 2026
- Method
- Methodology
Primary materials10
Supreme Court docket 20-1009
docket | Jul 25, 2026
Primary case document
Supreme Court document | Jul 25, 2026
CourtListener docket record
docket | Jul 25, 2026
Questions Presented
brief | May 24, 2026
opinion
opinion | May 23, 2022
Petition
brief | Jan 20, 2021
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026
SupremeCourt.gov
official | Jul 2, 2026