Trevino v. Thaler

Trevino v. Thaler, 569 US 413, was a 2013 United States Supreme Court decision that applied the narrow exception to Coleman v. Thompson's rule recognized by Martinez v. Ryan to excuse ineffective assistance of counsel (IAC) claims that were procedurally defaulted under Texas state law. Martinez recognized a right to counsel in an initial-review collateral proceeding where state law did not allow ineffective assistance of counsel (IAC) claims to be raised until post-conviction proceedings because there is no constitutional right to counsel in post-conviction proceedings. Even though Texas law allowed IAC claims to be raised on direct appeal the Court found that the state's procedures did not afford a "meaningful opportunity" to do so and held that the IAC claims raised for the first time in a federal habeas petition were not barred by the procedural default.