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Law School Case Brief

Strickland v. Washington - 466 U.S. 668, 104 S. Ct. 2052 (1984)

Rule:

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.

Facts:

After respondent Strickland was sentenced to death by a Florida state court on each of three counts of murder, to which he had pleaded guilty, and after the Florida Supreme Court affirmed the convictions and sentences, and after his application for state-court collateral relief was denied, and after the Florida Supreme Court affirmed the denial of relief, respondent petitioned for a writ of habeas corpus in the United States District Court for the Southern District of Florida, asserting ineffective assistance of counsel at and before his sentencing hearing. The District Court denied relief, but the United States Court of Appeals for the Eleventh Circuit reversed and remanded for new factfinding under newly announced standards for analyzing ineffective assistance claims. Petitioner sought further review.

Issue:

Whether a convicted defendant alleging ineffective assistance of counsel must show not only that counsel was not functioning as the counsel guaranteed by the Sixth Amendment so as to provide reasonably effective assistance but also that counsel's errors were so serious as to deprive the defendant of a fair trial because of a reasonable probability that, but for counsel's unprofessional errors, the results would have been different.

Answer:

Yes.

Conclusion:

On certiorari, the United States Supreme Court considered the proper standards for judging a criminal defendant's contention that the Constitution requires a conviction or death sentence to be set aside because counsel's assistance at the trial or sentencing was ineffective. The Court held that (1) a convicted defendant alleging ineffective assistance of counsel must show not only that counsel was not functioning as the counsel guaranteed by the Sixth Amendment so as to provide reasonably effective assistance but also that counsel's errors were so serious as to deprive the defendant of a fair trial because of a reasonable probability that, but for counsel's unprofessional errors, the results would have been different; and (2) neither branch was shown because the evidence which the defendant argued that counsel should have offered would have been of little help and would have allowed the introduction of other evidence, which counsel successfully moved to exclude, which would have been harmful to his case.

The Court held that respondent's failure to make the required showing of either deficient performance or sufficient prejudice defeated the ineffectiveness of counsel claim. Here there was a double failure. More generally, respondent made no showing that the justice of his sentence was rendered unreliable by a breakdown in the adversary process caused by deficiencies in counsel's assistance. Respondent's sentencing proceeding was not fundamentally unfair.

The Court concluded that the district court properly declined to issue a writ of habeas corpus. The judgment of the Court of Appeals was accordingly reversed.

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