Lawyer errors in death sentences
Cody James Martinez v. Thornell
In brief
- Where it stands
- Dismissed
Petition denied.
- What it’s about
- Cody James Martinez asked the Supreme Court to review his claims that Arizona used the wrong test to decide whether trial counsel’s errors harmed him and that he should be allowed to appeal the denial of sentencing relief on the kidnapping count after receiving relief on the murder count based on overlapping attorney-error findings.
- Who it affects
- Martinez gets no Supreme Court ruling on either claim, and the Court did not decide whether he is entitled to relief.
Summary: written with AI from the case record.

What it's about
The Court refused to hear the case (denied review) and did not decide either issue.
The trial court granted Martinez sentencing relief on the murder count but not the kidnapping count; Martinez argued that overlapping findings about his lawyer’s errors should also support an appeal on kidnapping.
Question presented
1. Whether Arizona, having refused Strickland cumulative error determination of prejudice, is entitled to AEDPA deference for a decision made using the wrong standard? 2. Whether Mr. Martinez has made a substantial showing of the denial of a constitutional right to support a certificate of appealability where the trial court granted sentencing relief as to Count 1 (Murder) but denied relief as to Count 2 (Kidnapping) even though its determination as to Count 1 (Murder) was based on a determination of ineffective assistance of trial counsel as to many of the same aggravating factors that resulted in the aggravated sentence as to Count 2 (Kidnapping)?
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Brief added: Petition
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.