Strickland v. Washington

Facts

Washington (D) planned and committed three groups of crimes, which included three brutal stabbing murders, torture, kidnapping, severe assaults, attempted murders, attempted extortion, and theft. After his two accomplices were arrested, D surrendered to police and voluntarily gave a lengthy statement confessing to the third of the criminal episodes. Counsel for D actively pursued pretrial motions and discovery. He cut his efforts short when he learned that, against his specific advice, D had also confessed to the first two murders. D was subject to indictment for three counts of first-degree murder and multiple counts of robbery, kidnapping for ransom, breaking and entering and assault, attempted murder, and conspiracy to commit robbery. D waived his right to a jury trial, again acting against counsel's advice, and pleaded guilty to all charges, including the three capital murder charges. In the plea colloquy, D told the trial judge that, although he had committed a string of burglaries, he had no significant prior criminal record and that at the time of his crime spree he was under extreme stress caused by his inability to support his family. Counsel advised D to invoke his right under Florida law to an advisory jury at his capital sentencing hearing. D rejected the advice and waived the right. He chose instead to be sentenced by the trial judge without a jury recommendation. Counsel spoke with D about his background. He also spoke on the telephone with D's wife and mother, though he did not follow up on the one unsuccessful effort to meet with them. He did not otherwise seek out character witnesses. Nor did he request a psychiatric examination, since his conversations with his client gave no indication that respondent had psychological problems. Counsel decided not to present and hence not to look further for evidence concerning respondent's character and emotional state. This reflected trial counsel's sense of hopelessness about overcoming the evidentiary effect of D's confessions to the gruesome crimes. Counsel reasoned that the plea colloquy communicated sufficient information about these subjects, and by forgoing the opportunity to present new evidence on these subjects, counsel prevented the State from cross-examining D on his claim and from putting on psychiatric evidence of its own. He successfully moved to exclude D's 'rap sheet.' D's criminal history would have undermined the claim of no significant history of criminal activity, he did not request that one be prepared. Counsel argued that D's remorse and acceptance of responsibility justified sparing him from the death penalty. Counsel also argued that respondent had no history of criminal activity and that respondent committed the crimes under extreme mental or emotional disturbance, thus coming within the statutory list of mitigating circumstances. He argued that D should be spared death because he had surrendered, confessed, and offered to testify against a codefendant. D was a good person who had briefly gone badly wrong in extremely stressful circumstances. The State put on evidence and witnesses largely for the purpose of describing the details of the crimes. Counsel did not cross-examine the medical experts who testified about the manner of death of D's victims. The trial judge found aggravating circumstances in that all three murders were especially heinous, atrocious, and cruel, all involving repeated stabbings. All three murders were committed in the course of at least one other dangerous and violent felony, and since all involved robbery, the murders were for pecuniary gain. All three murders were committed to avoid arrest for the accompanying crimes and to hinder law enforcement. In the course of one of the murders, D knowingly subjected numerous persons to a grave risk of death by deliberately stabbing and shooting the murder victim's sisters-in-law, who sustained severe - in one case, ultimately fatal - injuries. The trial judge found numerous aggravating circumstances and no mitigating circumstance. D was sentenced to death on each of the three counts of murder and to prison terms for the other crimes. The Florida Supreme Court upheld the convictions and sentences on direct appeal. D eventually filed a habeas corpus petition in federal court. The District Court concluded that, although trial counsel made errors in judgment in failing to investigate nonstatutory mitigating evidence further than he did, no prejudice to respondent's sentence resulted from any such error in judgment. The Fifth Circuit affirmed in part, vacated in part, and remanded with instructions to apply to the particular facts the framework for analyzing ineffectiveness claims that it developed in its opinion. The Circuit held that D must show that counsel's errors 'resulted in actual and substantial disadvantage to the course of his defense.' The court accordingly reversed the judgment of the District Court and remanded the case. The State of Florida filed a petition for a writ of certiorari seeking review of the decision of the Court of Appeals. The Supreme Court granted certiorari.

Issues

Rule of Law

Holding and Decision

Legal Analysis

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