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Criminal Procedure Keyed to Ohlin
Maples v. Thomas
Citation:565 U.S. 266 (2012)
In 1997, Alabama charged Maples with two counts of capital murder. Maples pleaded not guilty, and his case proceeded to trial, where he was represented by two court-appointed Alabama attorneys. Neither counsel had previously tried the penalty phase of a capital case. The jury recommended that he be sentenced to death. His appeal was denied. Two New York lawyers represented Maples in post-conviction proceedings. With the aid of his New York pro bono counsel, Maples filed a petition for post-conviction relief under Alabama rule. Maples asserted that his court-appointed attorneys provided constitutionally ineffective assistance during his capital trial. The State responded by moving for summary dismissal of Maples’ petition. The trial court denied the State’s motion. Some seven months later, both New York counsels left their firm. Neither attorney told Maples of their departure or of their resulting inability to continue to represent him. In disregard of Alabama law, neither attorney sought the trial court’s leave to withdraw.
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