Martinez v. Ryan, 132 S.Ct. 1309 (Mar. 20, 2012) (where state law requires a petitioner to raise a claim of ineffective assistance of trial counsel in an initial-review collateral proceeding, state procedural default will not bar a federal habeas court from hearing those claims if, in the initial-review collateral proceeding, there was no counsel or counsel in that proceeding was ineffective).

The court reaffirmed the importance of the right to counsel, when it stated:

A prisoners inability to present a claim of trial error is of particular concern when the claim is one of ineffective assistance of counsel. The right to the effective assistance of counsel at trial is a bedrock principle in our justice system. It is deemed as an obvious truth the idea that any person haled into court, who is too poor to hire a lawyer, cannot be assured a fair trial unless counsel is provided for him. Gideon v. Wainwright, 372 U. S. 335, 344 (1963). Indeed, the right to counsel is the foundation for our adversary system. Defense counsel tests the prosecutions case to ensure that the proceedings serve the function of adjudicating guilt or innocence, while protecting the rights of the person charged. See, e.g., Powell v. Alabama, 287 U. S. 45, 68"69 (1932) ([The defendant] requires the guiding hand of counsel at every step in the proceedings against him. Without it, though he be not guilty, he faces the danger of conviction because he does not know how to establish his innocence). Effective trial counsel preserves claims to be considered on appeal, see, e.g., Fed. Rule Crim. Proc. 52(b), and in federal habeas proceedings, Edwards v. Carpenter, 529 U. S. 446 (2000).

(Id. at 1317-18.)