Rompilla v. Beard

Brief Fact Summary.

Respondent Rompilla was convicted of murder. He appealed on the grounds that his counsel had not properly investigated mitigating factors.

Synopsis of Rule of Law.

“Even when a capital defendant and his family members have suggested that no mitigating evidence is available, his lawyer is bound to make reasonable efforts to obtain and review material that counsel knows the prosecution will probably rely on as evidence of aggravation at the trial’s sentencing phase.”

Facts.

Respondent Rompilla was indicted for murder, tried, and convicted. The prosecutor demonstrated three aggravating conditions. Defense counsel showed small evidence of mitigation. The jury found the aggravating conditions had greater weight and recommended the death penalty.
With new counsel, respondent filed an appeal on the grounds of ineffective assistance of counsel. The original counsel had not done enough to investigate very serious mitigating circumstances. The motion was denied by the appellate and then Pennsylvania Supreme Court. On a habeas appeal, petitioner argued that the Pennsylvania courts had improperly applied Strickland v. Washington. The District Court agreed, but the Third Circuit Court of Appeals reversed.

Issue.

Whether counsel for the defense had rendered ineffective counsel by not investigating more potential mitigating factors more thoroughly.

Held.

Yes. The Supreme Court of the United States first noted that the original counsel had relied too heavily on the uncooperative respondent and his family. The Court underscored this when it noted that the new counsel pursued “a number of likely avenues the trial lawyers could fruitfully have followed in building a mitigation case.” While the Court acknowledged that “reasonably diligent counsel may draw a line when they have good reason to think further investigation would be a waste,” it held that the lawyers were deficient in failing to examine the court file on Rompilla’s prior conviction.” This was underlined by the fact that appeals counsel followed those avenues. Furthermore, the trial counsel had been warned by the prosecutors that he would be using the information, and so “fell below the reasonable line of practice.”

Dissent.

The dissent argued that the Court “imposes on defense counsel a rigid requirement to review all documents in what it calls the ‘case file’ of any prior conviction that the prosecution might rely on at trial.”
Concurrence. Justice O’Connor responded to the dissent, writing that “today’s decision simply applies our longstanding case-by-case approach to determining whether an attorney’s performance was unconstitutionally deficient under Strickland v. Washington.”

Discussion.

“[T]he undiscovered ‘mitigating evidence, taken as a whole, ‘might well have influenced the jury’s appraisal’ of [Rompilla’s] culpability.’”