Page 10 (emphasis added): Thus, there are sound reasons for deferring consideration of ineffective assistance-of-trial-counsel claims until the collateral review stage, but this decision is not without consequences for the State's ability to assert a procedural default in later proceedings. By deliberately choosing to move trial ineffectiveness claims outside of the direct-appeal process, where counsel is constitutionally guaranteed, the State significantly diminishes prisoners' ability to file such claims. It is within the context of this state procedural framework that counsel's ineffectiveness in an initial-review collateral proceeding qualifies as cause for a procedural default.

Pages 13-14 (emphasis added): The rule of Coleman governs in all but the limited circumstances recognized here. The holding in this case does not concern attorney errors in other kinds of proceedings, including appeals from initial-review collateral proceedings, second or successive collateral proceedings, and petitions for discretionary review in a State's appellate courts. See 501 U. S., at 754; Carrier, 477 U. S., at 488. It does not extend to attorney errors in any proceeding beyond the first occasion the State allows a prisoner to raise a claim of ineffective assistance at trial, even though that initial-review collateral proceeding may be deficient for other reasons.

In addition, the limited nature of the qualification to Coleman adopted here reflects the importance of the right to the effective assistance of trial counsel and Arizona's decision to bar defendants from raising ineffective assistance claims on direct appeal. Our holding here addresses only the constitutional claims presented in this case, where the State barred the defendant from raising the claims on direct appeal.

So in lieu of the old Coleman line between direct appeal and collateral review we have a new line. Ineffective assistance as "cause" ends at direct review unless the claim is ineffective assistance of trial counsel and the appellant is barred by the rules from raising such a claim on direct appeal, in which case it ends at the trial court on the first collateral review.

What should we do from here? First, Arizona and any other state with a rule like the one in question here should repeal it, pronto. Allowing the appellant to make the claim on direct appeal as a theoretical matter, even though it will almost always be denied because it requires facts outside the record, is far less burdensome than litigating the effectiveness of both trial and collateral counsel in federal habeas.

Second, for states that do not have an Arizona-type rule (or have repealed theirs), press with vigor the statement quoted above: "The rule of Coleman governs in all but the limited circumstances recognized here." Lower federal courts have no authority to expand the Martinez exception beyond its limited terms. The strict Coleman rule continues to apply unless and until the Supreme Court says it does not. The opponents will, of course, quote Justice Scalia's dissent that the distinction between a state-rule bar and a practical impossibility "lacks any principled basis, and will not last," (footnote 1) but it lasts until the Supreme Court says otherwise.  The passage on page 10 quoted above says the difference is significant.

Third, Congress needs to amend 28 U.S.C. §2254(i) (addition in italics): "The ineffectiveness or incompetence of counsel during Federal or State collateral post-conviction proceedings shall not be a ground for relief in a proceeding arising under section 2254, and it shall not be cause for default allowing consideration of a claim otherwise barred for failure to properly raise it in state court." The parallel provision in Chapter 154, 28 U.S.C. §2261(e), requires a similar amendment.