The U.S. Supreme Court today issued a ruling favorable to habeas petitioners. The case is Massaro v. U.S. The text of the opinion is here.

An ineffective-assistance-of-counsel claim may be brought in a collateral proceeding under §2255, whether or not the petitioner could have raised the claim on direct appeal. Requiring a criminal defendant to bring ineffective-assistance claims on direct appeal does not promote the procedural default rule’s objectives: conserving judicial resources and respecting the law’s important interest in the finality of judgments. Applying that rule to ineffective-assistance claims would create a risk that defendants would feel compelled to raise the issue before there has been an opportunity fully to develop the claim’s factual predicate, and would raise the issue for the first time in a forum not best suited to assess those facts, even if the record contains some indication of deficiencies in counsel’s performance. A §2255 motion is preferable to direct appeal for deciding an ineffective- assistance claim.

The Court specifically held it was not limiting ineffective claims to habeas petitions as the issue was not before it--in cases where the ineffectiveness can be determined solely from the record, defendants can still raise it on direct appeal. Sounds like a win-win to us.