The U.S. Supreme Court on January 18, 2012, in the case of MAPLES v. THOMAS, COMMISSIONER, ALABAMA DEPARTMENT OF CORRECTIONS, (Case #10-63)https://www.supremecourt.gov/opinions/11pdf/10-63.pdf, reversed the U.S. Court of Appeals, For The 11th Circuit.
In the underlying trial for murder, the defendant was found guilty and sentenced to death by the Alabama Court. Thereafter, a world-renowned law firm, Sullivan and Cromwell, on a pro bono basis filed a Petition for post-conviction relief; it is noteworthy that they contended the defendant’s trial attorneys were inexperienced and incompetent, thereby depriving Maples of effective assistance of counsel as guaranteed by the Sixth Amendment of the U.S. Constitution. Later, the two attorneys associated with Sullivan and Cromwell separated from the firm, did not notify Maples and no one else substituted in as attorney. Then, the ruling on the Petition was denied and it was sent to the two former associates of the above law firm. However, none of the lawyers notified Maples and no one filed an official Notice of Withdrawal of Counsel. The time deadline to file a Notice of Appeal had since expired. Soon thereafter, the Alabama Assistant Attorney General wrote to Maples and alerted him he could still file a Writ of Habeas Corpus if he did so in a timely manner. At that point, Maples filed various pleadings in the State Courts and thereafter filed a Writ in the Federal District and U.S. Court of Appeals, both of which denied him any relief.
The U.S. Supreme Court distinguished the situation in which a lawyer’s negligence in failing to timely file a Notice of Appeal does not qualify as cause to excuse the error since the attorney is the agent of the inmate. Instead, the Supreme Court reasoned the failure on the part of the two lawyers to notify Maples of their departure from the law firm constituted abandonment and, therefore, sufficient cause or extraordinary circumstances beyond the control of Maples to relieve him of the procedural default in not filing a timely Notice of Appeal.