Shinn v. Ramirez

When Jones and Ramirez sought federal habeas relief, they confronted the collision of two ineffectiveness claims: their trial counsel's constitutional deficiency combined with their state post-conviction counsel's failure to develop evidence of that deficiency. The Court applied 28 U.S.C. Section 2254(e)(2)'s restriction strictly, holding that federal courts cannot supplement the state record with new evidence merely because state post-conviction counsel was ineffective in building it. Although Martinez v. Ryan created an exception for procedurally defaulted ineffective-assistance claims, Shinn confined that exception to the four corners of what was already presented in state court, foreclosing the petitioners' attempt to introduce outside evidence of their trial counsel's failures. The ruling thus locks the habeas court into the incomplete record created by both levels of counsel's deficiency, leaving no federal avenue to cure the evidentiary gaps.