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The Post-Aedpa Access-To-The-Courts Demand for a Constitutional Right to Counsel in Federal Habeas Corpus

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The Post-Aedpa Access-To-The-Courts Demand for a Constitutional Right to Counsel in Federal Habeas Corpus THE SACRIFICE OF UNARMED PRISONERS TO GLADIATORS: THE POST-AEDPA ACCESS-TO-THE-COURTS DEMAND FOR A CONSTITUTIONAL RIGHT TO COUNSEL IN FEDERAL HABEAS CORPUS Emily Garcia Uhrig* ABSTRACT This article argues for a constitutional right to counsel for state inmates in all initial federal habeas corpus proceedings based on access-to-the-courts doctrine. The doctrine guarantees an indigent inmate a constitutional right to meaningful access to the courts in incarceration-related litigation, including post-conviction proceedings. The Supreme Court initially articulated the access right, in relevant part, as merely prohibiting states from actively interfering with an indigent inmate’s efforts at pursuing post-conviction relief from a criminal judgment. Today, though still fairly inscrutable in dimension, the access right has evolved to require states in certain circumstances to provide affirmative assistance to inmates to ensure constitutionally adequate access to the writ. In Pennsylvania v. Finley1 and Murray v. Giarratano,2 a pair of decisions rendered in 1987 and 1989, respectively, the Supreme Court held that the right of access does not require assistance of counsel in either noncapital or capital state post-conviction proceedings, at least insofar as the inmate seeks to raise claims litigated on direct appeal. The primary rationale in Finley and Giarrantano was that habeas litigants have enjoyed assistance of counsel at trial and on direct appeal, and thus should be able simply to parrot that work product in the federal habeas forum to obtain judicial review of any cognizable claims. The Court analogized to an earlier case, Ross v. Moffitt,3 in which it had held no right to counsel attaches in discretionary appeals. The Court has never addressed the issue whether the access right demands assistance of counsel in federal habeas proceedings. But the lack of such right appeared a foregone conclusion after Finley and Giarratano. On April 24, 1996, however, Congress enacted the Antiterrorism and Effective Death Penalty Act of 1996 (“AEDPA”), which introduced a myriad of exceedingly complex procedural requirements -- most significantly, a one-year statute of limitations -- that a petitioner must satisfy in order to obtain merits review of claims set forth in a federal habeas petition. For the prototypical pro se habeas litigant, these requirements, in particular the statute of limitations, erected an impenetrable wall around federal judicial review of merits claims. Indeed, the effect of AEDPA’s enactment has been to stymie many pro se inmates’ efforts at obtaining federal habeas review of state court judgments. Yet, to date, the Supreme Court has not recognized a right to counsel in federal habeas corpus. Federal courts, while struggling mightily to make sense of a poorly drafted statute, * Associate Professor of Law, University of the Pacific, McGeorge School of Law. I am very grateful for the helpful comments and input of Ruth Jones, Linda Carter, Joanne Kir- chner, the participants of the Federal Courts Conference held at Michigan State Universi- ty, in particular Susan Bandes, who served as mentor for this Article, and Lumen M. Mul- ligan, who hosted the Conference, the faculty at Santa Clara University Law School, where I presented this Article in its early stages, and the assistance provided by my re- search assistants, Evelyn Grosenick, Diane Crawford, Spencer Tressler, Carrisa Bouwer, and Megan Cosgrove. 1219 1220 JOURNAL OF CONSTITUTIONAL LAW [Vol. 14:5 continue to abide by a literal fiction in assuming that most inmates are sufficiently competent to navigate post-AEDPA federal habeas practice without assistance of counsel. This article argues that absent constitutionally guaranteed assistance of counsel in federal habeas corpus and a concomitant remedy where that assistance falls short, AEDPA’s procedural intricacies function to deny the indigent, pro se state inmate the right to meaningful access to the courts in federal habeas proceedings. As such, absent repeal of AEDPA, the access right requires recognition of a right to assistance of counsel in filing a first federal petition. This right would extend only to navigating and comprehending the procedural complexity of federal habeas under AEDPA, rather than to the articulation and framing of substantive claims and subsequent litigation. TABLE OF CONTENTS INTRODUCTION ............................................................................ 1222 I. THE PROBLEM: THE IMPOSSIBLE TASK OF NAVIGATING AEDPA’S PROCEDURAL MORASS WITHOUT ASSISTANCE OF COUNSEL .................................................................................. 1224 A. The Lack of a Recognized Constitutional Right to Counsel in Federal Habeas Proceedings. ........ 1224 B. The Antiterrorism and Effective Death Penalty Act of 1996 ............................................................ 1227 C. Expecting the Impossible: The Introduction of a One-Year Statute of Limitations ........................ 1229 1. The Challenge of Figuring Out Even Where to Begin: Calculating the Elusive Triggering Date for the Statute of Limitations ............... 1230 2. Impediments to Filing: Once the Clock Has Started to Tick, What, if Anything, Will Cause it to Stop? ............................................. 1232 3. Necessary Efforts at Identifying Other Statute of Limitations Triggers ..................... 1234 a. Newly Recognized Constitutional Right 1234 b. Discovery of Factual Predicate ............... 1234 4. Unpacking the Doctrine of Statutory Tolling ............................................................ 1235 a. The Meaning of “Properly Filed” ........... 1236 b. Figuring Out What Qualifies for Statutory Tolling: The Scope of “Or Other Collateral Review” ........................ 1236 1 481 U.S. 551, 559 (1987). 2 492 U.S. 1, 12–13 (1989). 3 417 U.S. 600 (1974). Apr. 2012] POST-AEDPA RIGHT TO COUNSEL 1221 c. Interpreting “With Respect to the Pertinent Judgment or Claim” ............... 1238 d. Figuring Out the Meaning of “Pending”1239 5. Mining the Indeterminate Doctrine of Equitable Tolling ........................................... 1242 D. The Delicate Interplay Between AEDPA’s Statute of Limitations and Other Procedural Doctrines ............................................................... 1245 1. The Exhaustion Requirement ....................... 1246 2. AEDPA’s Proscription on Second or Successive Petitions ........................................ 1249 3. Procedural Default ......................................... 1250 E. The Prototypical Inmate ....................................... 1252 F. The Impact of AEDPA on the Number of Federal Habeas Petitions Being Dismissed on Procedural Grounds, and Thus Failing to Reach Merits Review ........................................................ 1254 II. ACCESS-TO-THE-COURTS DOCTRINE ....................................... 1256 A. Early Access Cases ................................................. 1258 B. Right to Counsel Cases ......................................... 1260 1. Right to Counsel at Trial ............................... 1260 2. Right to Counsel on Appeal .......................... 1261 C. Bridging Access-to-the-Courts and Right to Counsel Doctrines: Bounds v. Smith ..................... 1263 D. The Right of Access, Post-Bounds ......................... 1266 III. THE ACCESS-TO-THE-COURTS DEMAND FOR COUNSEL IN POST-AEDPA LITIGATION ..................................................... 1271 A. Providing Counsel ................................................. 1275 B. Providing a Remedy for Ineffective Assistance of Post-conviction Counsel ....................................... 1276 1. The Constitutional Requirement of Effective Assistance of Counsel ..................... 1276 2. Statutory and Equitable Relief from AEDPA’s Strictures ........................................ 1277 a. Relief from the Statute of Limitations ... 1277 b. Relief from Procedural Default Doctrine................................................... 1278 c. Policy-Based Reforms .............................. 1280 CONCLUSION ............................................................................... 1281 1222 JOURNAL OF CONSTITUTIONAL LAW [Vol. 14:5 INTRODUCTION The impetus for this Article derives from my work as a staff attor- ney with the Ninth Circuit Court of Appeals, where I was responsible for reviewing requests for certificates of appealability, which are re- quired by statute in order to appeal district court denials of federal habeas corpus petitions, and making recommendations to motions panels regarding whether the certificates should issue. This work re- quired my review of federal petitions and the district court rulings. In the more than four years I spent at the court, I reviewed and pre- sented to motions panels over 800 petitions. Virtually all of these pe- titions were prepared pro se, often handwritten on court-issued forms or typed out on old typewriters. As a lawyer with substantial expe- rience in the federal criminal justice system,4 by far the most chal- lenging issues for me to unpack were procedural in nature. Difficul- ties frequently emerged from the thin language of the governing statute, 28 U.S.C. §§ 2244 and 2253–2255, as amended by the Antiter- rorism and Effective Death Penalty Act of 1996 (“AEDPA”),5 and the number of unresolved questions that have resulted. Typically, once— or rather, if—the litigant cleared the procedural hurdles, the appro- priate disposition of the merits of a particular petition became readily apparent.
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