Rompilla v. Beard Case Brief

Why is the case important?

Respondent Rompilla was convicted of murder. He appealed on the grounds that his counsel had not properly investigated mitigating factors.

Facts of the case

A Pennsylvania court convicted Ronald Rompilla of murder. During the sentencing phase, the prosecution presented to the jury Rompilla’s previous rape and assault conviction, as an aggravating factor to justify the death sentence. The jury sentenced Rompilla to death and the state supreme court affirmed. Rompilla’s new lawyers filed an additional appeal, arguing that Rompilla’s trial counsel had been ineffective for failing to present mitigating evidence about his various personal problems. The state courts found that Rompilla’s counsel had sufficiently investigated mitigation possibilities. After Rompilla filed a federal habeas petition, a district court reversed the sentence and ruled the state supreme court had unreasonably applied the U.S. Supreme Court’s 1984 decision in Strickland v. Washington. Had the state court followed that case, the district court ruled, the court would have found Rompilla’s trial counsel ineffective for failing to investigate obvious signs of Rompilla’s troubled childhood, mental illness and alcoholism. The Third Circuit reversed.

Question

Whether counsel for the defense had rendered ineffective counsel by not investigating more potential mitigating factors more thoroughly.

Answer

Yes. The Supreme Court of the United States first noted that the original counsel had relied too heavily on the uncooperative respondent and his family. The Court underscored this when it noted that the new counsel pursued a number of likely avenues the trial lawyers could fruitfully have followed in building a mitigation case. While the Court acknowledged that reasonably diligent counsel may draw a line when they have good reason to think further investigation would be a waste, it held that the lawyers were deficient in failing to examine the court file on Rompilla’s prior conviction. This was underlined by the fact that appeals counsel followed those avenues. Furthermore, the trial counsel had been warned by the prosecutors that he would be using the information, and so fell below the reasonable line of practice.

Conclusion

The Court held that counsel had a duty to make all reasonable efforts to learn what they could about the offense, including obtaining the prior conviction file to discover any mitigating evidence and to anticipate the aggravating details. Given that defense counsel had notice of the death penalty, the conviction file showed prior rape and assault convictions, and the file was a readily accessible public document, the lawyers were deficient in failing to examine that file. Without this information, a convincing residual doubt argument impossible. Thus, the Commonwealth courts were objectively unreasonable in concluding that counsel could reasonably decline to make any effort to review the file. Moreover, the file also included mitigation leads that no other source suggested and would have prompted further investigation. The undiscovered mitigating evidence might well have influenced the jury’s appraisal of the petitioner’s culpability.

  • Case Brief: 2005
  • Petitioner: Ronald Rompilla
  • Respondent: Jeffrey A. Beard, Secretary, Pennsylvania Department of Corrections
  • Decided by: Rehnquist Court

Citation: 545 US 374 (2005)
Granted Sep 28, 2004
Argued: Jan 18, 2005
Decided: Jun 20, 2005