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This Week on First Street: SCOTUS Decides Maples v. Thomas

By Robyn Hagan Cain on January 19, 2012 | Last updated on March 21, 2019

The Nine released three more 2012 Supreme Court opinions yesterday, including a decision in a closely-watched criminal law matter.

In a 7-2 decision, the Court overturned the Eleventh Circuit Court of Appeals to find that death row inmate Cory Maples was entitled to another shot at his ineffective counsel appeal.

The case gained national media attention due to the highly unusual circumstances surrounding Maples' appeal.

Two attorneys from New York BigLaw powerhouse Sullivan & Cromwell were representing Maples pro bono in his murder conviction appeal because Alabama -- the state where Maples was tried --is the only state in the country that does not afford capital defendants the benefit of taxpayer-funded appeals.

The Sullivan & Cromwell attorneys severed their relationships with the firm without notifying the court or Maples. When Alabama sent notice to the firm that Maples' appeal had been denied, the letter was returned. Maples' Alabama attorney, who was representing Maples in name only to allow the New York attorneys to proceed pro hac vice, was also unaware that the New York attorneys had abandoned Maples, and failed to appeal.

While the Court generally attributes an attorney's successes and failures to his client during the course of representation, the majority ruled that doing so would be unfair in this case. Here, the Court decided that in cases in which the principal-agent relationship is severed, the absent attorney's acts or omissions "cannot be fairly attributed to the client." Furthermore, the client should not be faulted for failing to act on his own behalf in such scenarios when he had no reason to know that his attorneys had abandoned him.

There were two other noteworthy 2012 Supreme Court opinions on Wednesday:

  • Golan v. Holder. In a case addressing the amount of time that copyright holders should enjoy protection under the Copyright Act, the Court affirmed a Tenth Circuit Court of Appeals holding that Congress has the authority to restore lapsed copyrights. The opinion is largely a regurgitation of the Court's 2003 Eldred v. Ashcroft decision, reports The Volokh Conspiracy.
  • Mims v. Arrow Financial Services. In its second Eleventh Circuit reversal of the day, a unanimous Court held that the Telephone Consumer Protection Act's grant of jurisdiction to state courts does not deprive U.S. district courts of federal-question jurisdiction over private TCPA lawsuits.

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