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