Law School Case Brief
Strickland v. Washington - 466 U.S. 668, 104 S. Ct. 2052 (1984)
A convicted defendant's claim that counsel's assistance was so defective as to require reversal of a conviction or death sentence has two components. First, the defendant must show that counsel's performance was deficient. This requires showing that counsel made errors so serious that counsel was not functioning as the counsel guaranteed the defendant by the Sixth Amendment. Second, the defendant must show that the deficient performance prejudiced the defense. This requires showing that counsel's errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable.
Defendant Strickland, during a ten-day period, committed three groups of crimes, including three brutal capital murders, torture, kidnapping and attempted murders. Defendant pled guilty to all crimes and, stated that he accepted responsibility for the crimes and had only acted under extreme mental stress resulting from his inability to care for his family. Against the advice of his counsel, he waived his right to an adversarial jury at his sentencing hearing, and chose to be sentenced by the Judge. Because defendant had already claimed extreme mental stress, his counsel used that, along with information from his wife and mother to establish his character, but defense counsel did not request psychiatric evaluation, did not look for further mitigating evidence, and did not request a pre-sentencing report. Counsel’s decisions were said to reflect his hopelessness after his client pled to all offenses. Strickland was sentenced to death, and he sought habeas corpus relief due the failures of his counsel to come up with mitigating evidence.
After a defendant has pled guilty in a capital murder case, does defense counsel have a duty to present mitigating evidence, in order to meet the Sixth Amendment standard for effectiveness.?
On appeal, the death sentence was affirmed. In support of its ruling, the Supreme Court held that in order to show that counsel's assistance was so defective as to require reversal of a death sentence, defendant must have shown counsel's performance was deficient, and that such deficient performance prejudiced the defense. In applying this standard, the Court further held that defense counsel's performance could not be deemed unreasonable, and even if such were the case, defendant suffered insufficient prejudice to warrant setting aside his death sentence. In addition, in failing to make a showing that the justice of his sentence was rendered unreliable by a breakdown in the adversary process caused by deficiencies in counsel's assistance, defendant also failed to show that his sentencing proceeding was fundamentally unfair.
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