Watson v. State’s Empirical Analysis

Citation profile

54 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 54 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In March 2012, the United States Supreme Court decided Martinez, holding in part that “when a State requires a . prisoner to raise an ineffective-assistance-of-trial-counsel claim in a collateral proceeding, a prisoner may establish cause for a default of an ineffective-assistance claim where the state courts did not appoint counsel in the initial-review collateral proceeding for a claim of ineffective assistance at trial.” Martinez, 132 S.Ct. at 1318 . In other words, where state law bars a defendant from raising claims of ineffective assistance of trial counsel on direct appeal, “a procedural default will not bar a federal habe-as court from hearing a substantial claim of ineffective assistance at trial if, in the initial-review collateral proceeding, there was no counsel or counsel in that proceeding was ineffective.” Id., 132 S.Ct. at 1320 ; see also Dansby v. Norris, 682 F.3d 711, 729 (8th Cir.), adhered to on denial of reh’g sub nom. Dansby v. Hobbs, 691 F.3d 934 (8th Cir.2012). In 2013, the Supreme Court revisited the procedural-default issue in Trevino and stated that the Martinez Court had read the previous decision in Coleman v. Thompson, 501 U.S. 722 , 111 S.Ct. 2546 , 115 L.Ed.2d 640 (1991) “as containing an exception, allowing a federal habeas court to find “cause,” thereby excusing a defendant’s procedural default, where (1) the claim of “ineffective assistance of trial counsel” was a “substantial” claim; (2) the “cause” consisted of there being “no counsel” or ”

   1 later decision quote this exact passage · from the majority
   e.g. Mancia v. State

2. “An appellant cannot change the grounds for an argument for the first time on appeal.”

   1 later decision quote this exact passage · from the majority
   e.g. Woods v. State