Williams v. Taylor

Brief Fact Summary. Terry Williams (“Mr. Willliams”) was convicted of capital murder and received a death sentence for robbery and murder in Virginia in 1985. On appeal, Mr. Williams claimed ineffective assistance of counsel because his attorney failed to introduce certain mitigating evidence during the sentencing portion of his trial.

Synopsis of Rule of Law. A federal habeas writ may issue only when the state court decision was contrary to or involved an unreasonable application of clearly established Federal law as determined by the United States Supreme Court (“Supreme Court”).

Facts. Mr. Williams was sentenced to death for robbery and murder of Harris Stone (“Mr. Stone”) on November 3, 1985, in Danville, Virginia. Mr. Williams killed Mr.Stone with a mattock and robbed him after Mr. Stone refused to lend him money. Mr. Williams filed for state collateral relief in Danville Circuit Court arguing that his attorney was ineffective for failing to offer certain mitigating evidence at sentencing. After an evidentiary hearing on the issue, the State Circuit court found his trial attorney ineffective at the sentencing phase. The Virginia Supreme Court, while assuming the trial counsel was ineffective, disagreed with the trial judge’s conclusion that Mr. Williams suffered sufficient harm to warrant relief. Williams sought a federal writ of habeas corpus pursuant to 28 U.S.C. Section:2245, and the federal trial judge granted relief. The Federal Court of Appeals reversed the decision and sided with the Virginia Supreme Court.
The evidence not offered at sentencing by Mr. Williams’ attorney included facts regarding his childhood, mental capacity, lack of education, prison behavior record, and favorable testimony from prison officials.

Issue. Was Mr. Williams’ constitutional right to the effective assistance of counsel violated?
Was the decision of the Virginia Supreme Court in refusing to set aside Mr. Williams’ death sentence contrary to, or did it involve an unreasonable application of, clearly established Federal law, as determined by the Supreme Court, within in the meaning of 28 U.S.C. Section:2254(d)(1)?

Held. The Supreme Court, with different majorities of Justices for each holding, held that Mr. Williams had been deprived of the constitutional right to the effective assistance of counsel.
The Virginia Supreme Court’s refusal to set aside the death sentence was contrary to or involved an unreasonable application of clearly established federal law, as determined by the Court.

Dissent. Chief Justice Rehnquist (“J. Rehnquist”) issued a concurring and dissenting opinion in which Justice Antonin Scalia (“J. Scalia”) and Justice Clarence Thomas (“J. Thomas”) joined. J. Rehnquist disagreed with the decision to grant habeas relief arguing that the Virginia Supreme Court’s decision was not contrary to or an unreasonable application of Strickland.
Concurrence. Justice Sandra Day O’Connor (“J. O’Connor”) also issued a concurrence to note her disagreement with Justice John Paul Stevens (“J. Stevens”) on the standard the Court should apply in evaluating Mr. Williams’ habeas claim. J. O’Connor argues that Mr. Stevens’ construes the “contrary to” clause in a manner that causes the “unreasonable application” clause to have no meaning.

Discussion. In concluding that Mr. Williams’ attorney was ineffective within the meaning of Strickland v. Washington, the Supreme Court noted that the lower court should have relied on Strickland in deciding the ineffective assistance claim. Further, the lower court failed to fully evaluate and give appropriate consideration to the mitigating evidence.

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