Steak `N Shake No. 315 v. Ronald E. Smith (mem. dec.)

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that the exceptions to Coleman as announced in Martinez v. Ryan, 566 U.S. 1 (2012), and Trevino v. Thaler, 569 U.S. 413, 429 (2013), do not apply to ineffective assistance of counsel claims brought in Illinois
• noting that, in Illinois, “[i]f the claim relies solely on the existing record, it must be brought on direct appeal.”
• observing that a factor is “external to the defense” only if it “cannot fairly be attributed to” the defendant
• observing that cause sufficient to set aside a default only applies to factors that “cannot fairly be attributed to the prisoner”
• finding that “Illinois law gives prisoners a meaningful opportunity to litigate claims of ineffective assistance of trial counsel on direct review” such that the Martinez-Trevino exception to postconviction IAC claims does not apply
• calling \the rule of procedural default [ ] an important corollary to the exhaustion requirement\

Source: CourtListener parenthetical corpus (CC0).