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”).
The prevalent modern philosophy of penology is that the punishment should fit the offender and not merely the crime.View Full Point of Law
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.