Law School Case Brief
Rompilla v. Beard - 545 U.S. 374, 125 S. Ct. 2456 (2005)
Under 28 U.S.C.S. § 2254, ineffective assistance of counsel in federal habeas relief turns on showing that the state court's resolution of his claim of ineffective assistance of counsel under Strickland v. Washington, resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law. An "unreasonable application" occurs when a state court identifies the correct governing legal principle from the Supreme Court's decisions but unreasonably applies that principle to the facts' of petitioner's case. That is, the state court's decision must have been not only incorrect or erroneous but objectively unreasonable.
During the penalty phase of the trial of an accused who had been convicted in a Pennsylvania state court of murder and related offenses, the prosecution, seeking the death penalty, presented evidence of aggravating factors that (1) the murder had been committed during a felony, (2) the murder had been committed by torture, and (3) the accused had a significant history of felony convictions indicating the use or threat of violence. In mitigation evidence presented by the two lawyers who served as the accused's defense counsel at trial, five members of the accused's family argued in effect for residual doubt and beseeched the jury for mercy. However, the jury, assigning greater weight to the aggravating factors, sentenced the accused to death. The Pennsylvania Supreme Court affirmed the convictions and the sentence. The accused, asserting ineffective assistance by his trial counsel in failing to present significant mitigating evidence, sought state postconviction relief. A state court denied relief, and the Pennsylvania Supreme Court affirmed this denial. The accused, again asserting ineffective assistance of trial counsel, then sought federal habeas corpus relief under 28 U.S.C.S. § 2254. The United States District Court for the Eastern District of Pennsylvania (1) found that the Pennsylvania Supreme Court had unreasonably applied Strickland v. Washington (1984) 466 U.S. 668, 80 L. Ed. 2d 674, 104 S. Ct. 2052 (requiring accused alleging ineffective assistance of counsel, in violation of the Federal Constitution's Sixth Amendment, to show both failure to provide reasonably effective assistance and reasonable probability of different result if assistance had been reasonably effective); (2) determined that trial counsel had not investigated obvious signs of the accused's troubled childhood, mental illness, and alcoholism, and (3) granted the requested relief.
Did the lawyers ineffectively assist the accused?
The Court held that counsel had a duty to make all reasonable efforts to learn what they could about the offense, including obtaining the prior conviction file to discover any mitigating evidence and to anticipate the aggravating details. Given that defense counsel had notice of the death penalty, the conviction file showed prior rape and assault convictions, and the file was a readily accessible public document, the lawyers were deficient in failing to examine that file. Without this information, a convincing residual doubt argument impossible. Thus, the Commonwealth courts were objectively unreasonable in concluding that counsel could reasonably decline to make any effort to review the file. Moreover, the file also included mitigation leads that no other source suggested and would have prompted further investigation. The undiscovered mitigating evidence might well have influenced the jury's appraisal of the petitioner's culpability.
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