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Hinton v. Alabama - 571 U.S. 263, 134 S. Ct. 1081 (2014)

Rule:

Under the Strickland rule, a criminal defendant’s Sixth Amendment right to counsel is violated if his trial attorney’s performance falls below an objective standard of reasonableness and if there is a reasonable probability that the result of the trial would have been different absent the deficient act or omission.  

Facts:

In 1985, several restaurant robberies coupled with shooting occurred in Birmingham. On these several occasions, the restaurant managers were killed with a .38 caliber bullets. One manager, named Smotherman, survived the robbery-shooting; he later identified defendant Anthony Hilton in a photographic array as the perpetrator. The police arrested Hinton and recovered from his house a .38-caliber revolver belonging to his mother, who shared the house with him. After analyzing the six bullets fired during the three crimes and test-firing the revolver, examiners at the State’s Department of Forensic Sciences concluded that the six bullets had all been fired from Hinton’s gun. Consequently, Hinton was charged two counts of capital murder for the killings during the first two robberies. During trial, the State linked Hinton to the Smotherman robbery through eyewitness testimony and forensic evidence about the bullets fired at Smotherman and then to persuade the jury that, in light of the similarity of the three crimes and forensic analysis of the bullets and the Hinton revolver, Hinton must also have committed the two murders. Recognizing that Hinton’s defense called for an effective rebuttal of the State’s expert witnesses, Hinton’s attorney filed a motion for funding to hire an expert witness of his own. In response, the trial judge granted $1,000. Using the money provided for by the trial judge, Hinton’s attorney presented an “expert witness” whose credibility and expertise were not established and proven. The jury convicted Hinton and recommended by a 10-to-2 vote that he be sentenced to death. The trial judge accepted that recommendation and imposed a death sentence. In his state post-conviction petition, Hinton contended that his trial attorney was ineffective to not seek additional funds when it became obvious that the individual willing to examine the evidence in the case for the $1,000 allotted by the court was incompetent and unqualified. The Circuit Court of Alabama denied Hinton’s post-conviction petition on the ground that Hinton had not been prejudiced by his defense attorney's allegedly poor performance; this decision was affirmed by the The Alabama Court of Criminal Appeals.  Defendant filed a petition for a writ of certiorari to the United States Supreme Court.

Issue:

Was the defendant’s trial counsel ineffective, in light of his failure to obtain a more credible expert witness to testify at the trial?

Answer:

Yes.

Conclusion:

The Court held that trial counsel’s failure to request additional funding in order to replace an expert he knew to be inadequate because he mistakenly believed that he had received all he could get under Ala. Code § 15-12-21(d) constituted deficient performance. Specifically, the Court posited that trial counsel knew he needed additional funding to present an adequate defense, yet he failed to make even the cursory investigation of the state statute providing for defense funding for indigent defendants that would have revealed to him that he could have received reimbursement not just for $1,000, but for any expenses reasonably incurred. In this case, the Court held that the inadequate assistance of counsel was the inexcusable mistake of law, i.e., the unreasonable failure to understand the resources that state law made available to him that caused counsel to employ an expert that he himself deemed inadequate.

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