Roberto Mata v. Tyrone Baker

Summary

The Seventh Circuit held that a habeas petitioner procedurally defaulted his ineffective assistance of trial counsel claim when the Illinois Appellate Court applied the state’s waiver doctrine, finding the claim could have been raised on direct appeal—an adequate and independent state procedural ground barring federal review. The court also found the petitioner’s separate claim of ineffective assistance of appellate counsel was procedurally defaulted because he failed to raise it in his petition for leave to appeal to the Illinois Supreme Court, and thus could not serve as cause to excuse the default. The ruling affirms the district court’s denial of habeas relief under 28 U.S.C. § 2254.

Questions Presented

1. Whether Mata procedurally defaulted his ineffective assistance of trial counsel claim by failing to raise it on direct appeal, and whether the Illinois Appellate Court's waiver determination was an adequate and independent state ground barring federal habeas review.
2. Whether Mata's ineffective assistance of appellate counsel claim was procedurally defaulted for failure to exhaust state remedies.