Strickland v. Washington

Brief Fact Summary.

After being sentenced to death, Petitioner filed for a writ of Habeas Corpus on the grounds that he was given ineffective assistance of counsel.

Synopsis of Rule of Law.

error, alone, is not sufficient to prove that a defendant was deprived of their constitutional right to effective assistance of counsel.

Facts.

Respondent, Strickland, during a ten-day period, committed three groups of crimes, including three brutal capital murders, torture, kidnapping and attempted murders. Respondent pled guilty to all crimes and, stated that he accepted responsibility for the crimes and had only acted under extreme mental stress resulting from his inability to care for his family. Against the advice of his counsel, he waived his right to an adversarial jury at his sentencing hearing, and chose to be sentenced by the Judge. Because the defendant had already claimed extreme mental stress, his counsel used that, along with information from his wife and mother to establish his character. He did not request psychiatric evaluation, did not look for further mitigating evidence, and did not request a pre-sentencing report. Counsel’s decisions were said to reflect his hopelessness after his client pled to all offenses. Strickland was sentenced to death, and he sought habeas corpus relief due the failu
res of his counsel to come up with mitigating evidence.

Issue.

Whether, after a defendant has pled guilty in a capital murder case, counsel has a duty to present mitigating evidence, in order to meet the Sixth Amendment standard for effectiveness.

Held.

The Supreme Court, in an opinion authored by Justice O’Connor, held that while counsel may have committed error, it was not so ineffective as to overturn a death sentence.

Dissent.

Justices Brennan and Marshall dissented, holding that in the case of a capital crime, sentencing should be reconsidered if the counsel is found to have committed error.

Discussion.

In the course of her opinion, justice O’Connor fully delineated the rule on what the Sixth Amendment encompasses when it considers effective assistance:
First the benchmark for judging any claim of ineffectiveness must be whether the counsel’s conduct so undermined the proper functioning of the judicial process that the entire trial cannot be relied upon as just in result;

Next the defendant must meet a two prong test in order to show that assistance of counsel was so defective as to require reversal or setting aside of a death sentence: (1) the counsel’s performance must be deficient, and (2) that deficient performance must have prejudiced the defendant so much as to have deprived him of a the right to a fair trial;

When judging the performance of an attorney, counsel must be given a great deal of latitude, considering all circumstances. each case must be considered on a case-by-case basis; and

Also, in a federal habeas challenge to a state criminal judgment, a state court conclusion that counsel rendered effective assistance is not a finding of fact binding on the federal court, but it is a mixed question of law and fact.