Strickland v. Washington
Following is the case brief for Strickland v. Washington, 466 U.S. 668 (1984)
Case Summary of Strickland v. Washington:
- Defendant Washington was arrested for a number of crimes he committed in a 10-day crime spree. He ultimately pleaded guilty.
- At sentencing, the defendant’s attorney did not obtain character witnesses or order a pre-sentence report. The judge then sentenced the defendant to the death penalty.
- When all of his direct appeals were exhausted, the defendant claimed ineffective assistance of counsel in federal court.
- Once the case came to the U.S. Supreme Court, the Court held that ineffectiveness of counsel is determined by deciding (i) whether counsel’s representation was objectively deficient, and (ii) whether, but for counsel’s deficient performance, the result of the proceeding would have been different.
- Applying that test to the facts, the Court held that counsel’s choices were not deficient; and that even if they were, they would not have changed the outcome of the case.
Strickland v. Washington Case Brief
Statement of the Facts:
Defendant Washington engaged in a 10-day crime spree, that included a number of violent crimes. He also later confessed to two murders he committed during the spree. Once he decided to plead guilty, the defendant told the judge that he committed the crimes under a great deal of stress for the welfare of his family. The judge appeared impressed that the defendant took responsibility for his crimes.
The defendant waived a sentencing jury, and chose to have the judge impose sentence. In preparation for the sentencing hearing, the defendant’s attorney did not obtain character witnesses, nor did he order a pre-sentence report. He did so because he believed that the judge liked that the defendant took responsibility, and he did not want the pre-sentence report to emphasize the defendant’s prior criminal history.
The judge, following the hearing, imposed the death penalty. The defendant exhausted all of his direct appeals without getting the sentence overturned.
Procedural History:
- The defendant filed a habeas corpus petition in federal district court, claiming that his counsel was ineffective. The district court denied relief.
- The Eleventh Circuit Court of Appeals ultimately reversed. It outlined the standard for ineffectiveness of counsel, and remanded the case to the district court to review based on the standards it outlined.
- Officials from the State of Florida filed a petition for certiorari in response to the Court of Appeals decision.
- The U.S. Supreme Court granted certiorari.
Issue and Holding:
Was the defendant’s counsel ineffective during the sentencing hearing? No.
Judgment:
The decision of the Eleventh Circuit Court of Appeals is reversed.
Rule of Law or Legal Principle Applied:
A counsel’s performance is ineffective if (1) the counsel’s performance was objectively deficient, and (2) but for counsel’s unprofessional errors, the outcome of the case would have been different.
Reasoning:
The right to counsel under the Sixth Amendment means the right to effective counsel. Further, the fundamental principle supporting the Sixth Amendment right to counsel is to provide a fair trial.
The test of whether a counsel’s assistance was so defective as to require reversal of a conviction or a death sentence has two parts:
- The defendant must show that counsel’s performance was objectively deficient, meaning counsel made errors that were so serious that counsel was not functioning as a counsel as intended by the Sixth Amendment; and
- The defendant must show that the deficient performance prejudiced the defense. In other words, a court must decide that, but for counsel’s unprofessional errors, the outcome of the case would have been different.
Applying that standard to the facts in this case, it is clear that the defendant’s counsel was not deficient. Counsel made decisions that, while not an approach others would have taken, at least were reasonable enough not to be considered deficient for Sixth Amendment purposes.
Also, even if counsel’s errors were objectively deficient, the defendant’s sentence would not have changed if counsel made different choices. The facts against defendant were too strong in this case.
It should be noted that counsel should be given some latitude regarding the range of professional conduct that is considered reasonable. Also, if a case can be disposed of by jumping to the second part of the test above, that would be appropriate for a court to do.
Concurring and Dissenting Opinions:
Concurring and Dissenting Opinion (Brennan):
The Court’s two-part test for ineffective assistance of counsel is appropriate, and the Court’s application of the test is correct. However, because the death penalty is at all times unconstitutional, the sentence should not be imposed in this case.
Dissenting Opinion (Marshall):
The Court’s two-part test is so vague and flexible as to be essentially useless and lead to unpredictable results in practice. Moreover, because this is a death penalty case, it should be treated differently because any error cannot be undone.
Significance:
Strickland v. Washington is a landmark decision because it set the standard for courts in determining ineffective assistance of counsel. Despite Justice Marshall’s dissenting opinion to the contrary, the Court’s two-part test has stood the test of time. In fact, over three decades later, it is used to this day to determine claims of ineffective assistance of counsel.
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