This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
The majority held that a prisoner must be “at fault” for an undeveloped state‑court record to satisfy § 2254(e)(2).
The majority also held that attorney negligence is chargeable to the client and precludes relief unless the conditions of § 2254(e)(2) are satisfied.
Justice Sotomayor’s dissent argues that the Court overstates the harm to states that would result from allowing prisoners to develop evidence outside the narrow exceptions of § 2254(e)(2).
Background and question before the Court
According to Petitioner (Brunn W. Roysdon, Solicitor General), according to Petitioner (Brunn W. Roysdon, Solicitor General), the petition framed the case as a question of statutory interpretation, arguing that § 2254(e)(2) creates a high bar for federal evidentiary hearings on habeas claims involving state convictions.
According to Justice Sotomayor, the Court needed to determine what “at fault” means under § 2254(e)(2).
What each side argues
Petitioner Argument
According to Petitioner (Brunn W. Roysdon, Solicitor General), according to Petitioner (Brunn W. Roysdon, Solicitor General), the petitioner (Arizona) argues that § 2254(e)(2) imposes a stringent requirement for federal evidentiary hearings, limiting them to narrow statutory exceptions.
What happened at oral argument
Justice Thomas asked why the Court would excuse a default under Martinez but not allow the prisoner to develop the evidentiary basis for his claim.
According to Justice Sotomayor, justice Sotomayor questioned what constitutes “fault” under the statute, noting that the statute itself does not define the term.
Justice Alito asked whether a Sixth Amendment right to effective assistance of counsel in the first post‑conviction proceeding would affect the attribution of fault to the prisoner.
According to Justice Alito, justice Alito inquired about the issue the Court may have left open in *Coleman*, specifically whether the Sixth Amendment applies in the first post‑conviction proceeding or whether a non‑constitutional basis could relieve the prisoner of fault.
Justice Sotomayor asked about the rarity of “Martinez hearings,” noting that only two such cases occur per year.
What the Court decided
The Court interpreted “fail” to mean that the prisoner must be at fault for the undeveloped record in state court.
The Court held that attorney negligence is chargeable to the client and bars relief unless the conditions of § 2254(e)(2) are satisfied.
Justice Sotomayor’s dissent contended that the majority overstates the harm to states that would result from allowing prisoners to develop evidence outside the narrow exceptions of § 2254(e)(2).
Why it matters
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- 2bab1d001ec709196e7a-r1-131ee37282b85402.pdfopinion
- 30f689dd7285082ebcdf-r1-342187631083a1b5.pdforal argument transcript
Guide generated September 28, 2026. Automated validation accepted this version.