Maples v. Thomas

Maples (plaintiff), sentenced to death, was represented in state postconviction proceedings by two out-of-state attorneys who left their firm (and thus could no longer represent him) without notifying Maples or the court; when the state court denied relief, notice mailed to the departed attorneys was returned undelivered, and local counsel, who received notice, assumed the departed attorneys would handle any appeal and took no action, causing the appeal deadline to lapse. Maples's federal habeas petition was denied due to this procedural default, and the Eleventh Circuit affirmed.