Mickens v. Taylor Case Brief

Why is the case important?

Petitioner, Mickens, brought appeal after being sentenced to death when he learned that his trial counsel had previously represented his victim.

Facts of the case

A Virginia jury convicted Walter Mickens, Jr., of the premeditated murder of Timothy Hall during or following the commission of an attempted forcible sodomy and sentenced him to death. Subsequently, Mickens filed a federal habeas petition, alleging that he was denied effective assistance of counsel because one of his court-appointed attorneys had a conflict of interest at trial – his lead attorney, Bryan Saunders, had represented Hall on criminal charges at the time of the murder. Saunders had not disclosed to the court, his co-counsel, or Mickens that he had represented Hall. Ultimately, the en banc Court of Appeals rejected MIckens’s argument that the juvenile court judge’s failure to inquire into a potential conflict either mandated automatic reversal of his conviction or relieved him of the burden of showing that a conflict of interest adversely affected his representation. Subsequently, the appellate court concluded that Mickens had not demonstrated adverse effect.

Question

Whether an attorney’s conflict of interest necessarily leads to a reversible Sixth Amendment violation.

Answer

Affirmed. The court held that in order to demonstrate a Sixth Amendment violation, it is imcumbent upon the defendant to prove that he has been prejudiced by his counsel’s performance.

Conclusion

The United States Supreme Court held that the juvenile court’s judge failure to inquire into a potential conflict did not mandate automatic reversal of petitioner’s conviction. According to the Court, in order to demonstrate a Sixth Amendment violation where the trial court fails to inquire into a potential conflict of interest about which it knew or reasonably should have known, a defendant must establish that a conflict of interest adversely affected his counsel’s performance. A defendant alleging ineffective assistance generally must demonstrate a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.

  • Case Brief: 2002
  • Petitioner: Mickens
  • Respondent: Taylor
  • Decided by: Rehnquist Court

Citation: 535 US 162 (2002)
Argued: Nov 5, 2001
Decided: Mar 27, 2002