Monday, July 30, 2012

U.S. v. Ryan, No. 12-16562 (7-27-12) (Callahan with O'Scannlain and Graber)
Disclosure -- This is an AZ FPD case
The 9th affirms the denial of a second habeas petition, in which the petitioner raised a Martinez issue (IAC of PCR counsel).  The 9th focused, however, on the fact that the petitioner decided to represent himself at trial and sentencing, and so Martinez afforded no relief.


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