Law School Case Brief
Wiggins v. Smith - 539 U.S. 510, 123 S. Ct. 2527 (2003)
The United States Supreme Court has established the legal principles that govern claims of ineffective assistance of counsel in an ineffective assistance claim has two components: A petitioner must show that counsel's performance was deficient, and that the deficiency prejudiced the defense. To establish deficient performance, a petitioner must demonstrate that counsel's representation fell below an objective standard of reasonableness. The Court has declined to articulate specific guidelines for appropriate attorney conduct and instead have emphasized that the proper measure of attorney performance remains simply reasonableness under prevailing professional norms.
Petitioner state death row inmate sought federal habeas corpus relief claiming that his Sixth Amendment right to counsel by counsel's failure to investigate the inmate's background and present mitigating evidence of his unfortunate life history at his capital sentencing proceedings. The evidence would have shown severe privation and abuse in the first six years of his life while in the custody of his alcoholic, absentee mother, physical torment, sexual molestation, repeated rape during subsequent years in foster care, a period of homelessness, and diminished mental capacities. The trial court granted but the court of appeals reversed.
Does the counsel’s failure to consider mitigating evidence and expand the investigation beyond the pre-sentence report of the department of social services violate the right of petitioner under the Sixth Amendment?
The U.S. Supreme Court held that counsel's decision not to expand their investigation beyond the pre-sentence report and department of social services (DSS) records fell short of professional standards prevailing in the state. The mitigating evidence that counsel failed to discover and present was relevant to assessing the inmate's moral culpability. Given the nature and the extent of the abuse the inmate suffered, there was a reasonable probability that a competent attorney would have introduced it at sentencing. Moreover, had the jury been confronted with the evidence, a reasonable probability existed that it would have returned a different sentence.
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