Ryan v. Detrich
Petition for certiorari denied on May 27, 2014
Issue: (1) Whether the Ninth Circuit improperly held that
Martinez v. Ryan provides a
“more lenient rule . . . for excusing procedural default”
than does Coleman v. Thompson,
and encompasses both cause and prejudice to excuse
the procedural default of a habeas claim; and (2) whether the Ninth Circuit improperly removed the prejudice prong from an analysis of ineffective assistance of post-conviction counsel as provided in Martinez and Strickland v. Washington.