Trevino v. Thaler, 569 US 413, was a 2013 United States Supreme Court decision that applied the narrow exception to Coleman v. Thompson's rule recognized by Martinez v. Ryan to excuse ineffective assistance of counsel (IAC) claims that were procedurally defaulted under Texas state law.

Even though Texas law allowed IAC claims to be raised on direct appeal the Court found that the state's procedures did not afford a "meaningful opportunity" to do so and held that the IAC claims raised for the first time in a federal habeas petition were not barred by the procedural default.

[3] The majority decision emphasized the interest in the fairness of state processes and the availability of federal review for prisoners who did not have a "meaningful opportunity" to litigate an IAC claim.

Dissenting, Chief Justice John Roberts said the Court had been "unusually explicit about the narrowness" of the Martinez decision.

[4] On remand, Trevino's attorneys argued that the jury might have imposed a life sentence if evidence of fetal alcohol syndrome had been presented during the trial's penalty phase.