Law School Case Brief
People v. Baldi - 54 N.Y.2d 137, 444 N.Y.S.2d 893, 429 N.E.2d 400 (1981)
Trial tactics which terminate unsuccessfully do not automatically indicate ineffectiveness. So long as the evidence, the law, and the circumstances of a particular case, viewed in totality and as of the time of the representation, reveal that the attorney provided meaningful representation, the constitutional requirement will have been met.
In New York state court, defendant Joseph Baldi was convicted of attempted murder and burglary in one trial and of murder in a second trial, based on unrelated crimes committed 9 months apart. In both trials, defendant was represented by the same counsel, who concentrated on proving an insanity defense. The defense was rejected and defendant was convicted. Defendant obtained new counsel and appealed to the appellate division, arguing that his sanity had not been proven beyond a reasonable doubt and that defendant's trial counsel's conduct was such that it denied defendant the effective assistance of counsel. Although the proof-of-sanity question was decided against defendant, a majority of the appellate division determined as a matter of law that defendanthad been denied the effective assistance of counsel and reversed ordered both judgments of conviction. The People were granted leave to appeal. They argued that trial counsel's conduct at both trials was an innovative defense tactic, not an incompetent or ineffective performance.
Was defendant accorded effective assistance of counsel at his trials?
The state's highest court found that trial counsel's actions and tactics were well founded in law. The fact that counsel testified that defendant admitted to a number of other crimes was an attempt to establish the insanity defense which he had reasonably concluded was defendant's strongest defense. The court noted that two standards had developed for judging counsel's assistance: whether counsel's conduct rendered the trial a farce and a mockery of justice and whether counsel exhibited reasonable competence. The court did not select a standard but ruled that counsel's conduct was adequate under both standards.
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