Arizona Capital Representation Project

The Ninth Circuit Court of Appeals remanded Clabourne v. Ryan to the district court for consideration of whether Mr. Clabourne’s claim of ineffective assistance of sentencing counsel may be considered on the merits in light of Martinez v. Ryan. The Ninth Circuit denied relief on Mr. Clabourne’s remaining claims, including that the Arizona Supreme Court improperly applied a causal nexus requirement to his mitigating evidence. The opinion is below.

2014-03-05 Opinion